The beginning of 2015 saw companies scramble to meet GHS deadlines. The June 1 deadline for label and safety data sheets (SDS) compliance in both the U.S. and the EU is rapidly approaching. Also, The U.S. Occupational Safety & Health Administration (OSHA) recently denied some relief on that timeline.

It’s not all bad news, however. There is some good news that has come out of Canada so we will start our discussion there.

Aerosol classifications will be harmonized between the U.S. and Canada

There was a great deal of concern among the regulatory compliance industry that the Canadian implementation of the Globally Harmonized System of Classification & Labeling of Chemicals (GHS) would use aerosol classifications from the most updated version of the UN’s purple book and, in so doing, would cause the Canadian regulations for aerosols to significantly deviate from the US’s Hazcom 2012 regulation. One of our consultants, Mae Hrycak, expressed her concerns to Health Canada:

While reviewing the Proposed Hazardous Products Regulations (HPR) we have come across a discrepancy. Would you be able to provide clarification on the following?

The proposed Canadian HPR state that the 5th Revision of the Purple Book is going to be followed. The 5th revision includes a new Aerosol Classification (Aerosols/Aerosol 3) which is used instead of the Compressed Gas classification when you find your Aerosol is Not Flammable.

However, when you look in the HPR at the classification criteria for Aerosols [7.3.1 (1)], the Aerosol 3 class is not included. Should we proceed using the Aerosol classification criteria found in the Purple Book 5th revision or what is seen in the HPR?

We shortly received this response from Health Canada, assuring us that the 5th revision will not be used for this classification:

Thank you for your question regarding the classification of aerosols under the proposed HPR.

You are correct; the name of the hazard class in the proposed HPR is “Flammable Aerosols” rather than “Aerosols.” To classify flammable aerosols, a supplier should follow the criteria in the proposed HPR rather than the criteria found in the GHS (rev. 5).

The proposed HPR does refer to the 5th revision of the GHS Purple Book and the proposed Regulations are aligned with the GHS 5th revision with regard to the classification criteria and hazard communication elements for many of the hazard classes.

This is great news for the aerosol industry. The last thing any of us needed was to have two different sets of aerosol classifications between the U.S. and Canada. There are enough differences between Hazcom 2012 and the proposed Hazardous Products Regulations as it is!

OSHA denies general relief to manufacturers, will use enforcement powers on case-by-case basis

A request by the American Coatings Association (ACA) to modify enforcement policy and extend the deadline for Hazcom 2012 compliance was denied by OSHA. The issues identified here by the ACA will sound all too familiar to formulators:

ACA and the supporting trade associations were compelled to petition OSHA for relief due to the lack of updated hazard classifications for raw materials down the supply chain. When issuing the final rule, OSHA applied the same compliance date of June 1, 2015 for raw materials, intermediate mixtures and final formulated products. OSHA assumed that currently available data and expected early compliance would allow for sufficient time for product formulators to receive or locate the necessary HCS compliant SDS and then process the information to create new labels and SDS. Unfortunately, this scenario has not played out as OSHA expected. Compliance with the single deadline for many manufacturers of formulated products has been virtually impossible since manufacturers of individual raw materials are not required to provide SDS that conform to the new standard until the June 1, 2015 deadline for all manufacturers.

We have seen this all too often at Nexreg, where companies do not have access to the upstream information to ensure their SDS and labels are fully compliant with GHS. OSHA’s decision not to follow the EU in having a staggered phase-in for mixtures and substances has caused difficulty, and neither the EU nor the U.S. made allowances for the issue of intermediate mixtures. How are companies supposed to be Hazcom 2012 compliant when their upstream suppliers are tardy in providing them with Hazcom 2012 information on raw materials and intermediate mixtures?

To OSHA’s credit, they recognized the problem and have offered a solution:

OSHA is able to use its enforcement discretion when compliance staff consider whether formulators and manufacturers have performed their due diligence and made good faith efforts to obtain necessary information to comply with the June 1, 2015 deadline. Our policy allows us to consider barriers to the downstream flow of information that are beyond their control. Manufacturers and formulators should therefore document all efforts to alternatively obtain the required information such as: attempts to contact their supplier to obtain the proper information; reasonable efforts to find alternate suppliers who could provide timely and accurate classifications, and reasonable efforts to find relevant data themselves… The agency intends to apply the same approach to distributors that can demonstrate that they have received chemical labeled under this policy.

Here is our advice to companies that have not been able to obtain the information they need to ensure products have compliant labels and SDS:

Put all requests for information by mail or over e-mail, do not simply ask over the phone. The paper trail is absolutely crucial.

Proactively have documentation showing that other suppliers have been contacted to request this information or that there are no other suppliers with an equivalent product.

For documentation where no relevant data exists, it would be helpful to keep a memo on file showing that a search was undertaken, including:

The specific information that is lacking.

The form the search took (internet searches, phone calls, databases accessed, etc.)

Who undertook the search

When they undertook the search

In my next column, we will be examining updates to California’s Proposition 65 along with the final version of Canada’s Hazardous Products Act if released in the next three months. Until then, we will be working hard meeting GHS deadlines around the world!

EPA

The U.S. Environmental Protection Agency (EPA) held three hearings to discuss the changing of the new Ozone Standard. Currently the Ozone Standard is 75 parts per billion (ppb). This means that if the Ozone (O3) level in the air is higher than 75ppb, then the area in question is out of compliance with the Federal Clean Air Act. This requires the area, whether it is an air district as seen in California, or a county, state or other designated area, to develop and implement plans called State Implementation Plans (SIPs) to control emissions of Volatile Organic Compounds (VOCs) or Oxides of Nitrogen. These two compounds, in the presence of sunlight, create ozone.

Three meetings were held in Washington DC, Texas and California. I monitored the California meeting, which started at 9:00 am and was rumored to have gone until 9:00 pm; I left at 5:30 pm. The majority of speakers were from the public or from environmental groups such as the Sierra Club, Coalition for Clean Air and Mom’s for Clean Air. Also, a number of agencies testified, such as the Office of Environmental Health Hazed Assessment (OEHHA), California Air Resources Board (CARB) and Bay Area Air Quality Management District (BAAQMD). Very few industry people spoke.

The EPA is proposing to lower the ozone standard from 75ppb to between 65–70ppb. To reach a standard of 70ppb by 2025, the EPA is estimating a cost of $3.9 billion and $15 billion to meet the standard at 65ppb. This does not include California because of the severity of the area; California has until 2037 to meet the limits, which will cost an additional $800 million for the 70ppb standard and $1.6 billion for the 65ppb standard.

Almost all of the public and environmental comments were similar:

Petroleum and chemical plants are to blame.

We can go to electric cars tomorrow.

Solar energy and wind power are the answer.

Industry can adjust.

In addition, most speakers were asking for 60ppb to be the standard. This is a state that cannot even meet 75ppb. Also, numerous speakers were from high schools; these children testified that industry is holding everything back and that they are entitled to clean air! I kept wondering, do these children have parents who work? Do these children ever want to drive a car? Do they really believe that if industry could move to newer technology that we would not? It is sad that so many children have this perception of the industry. Industry needs to respond to the EPA in force on this issue, as well as start educating our children on reality.

Written comments are due by March 17, 2015. When the Ozone Standard is lowered, this will mean more jurisdictions across the country will need more emission reductions. View the EPA’s Ozone map at www.spraytm.com by clicking on the “Regulatory Issues” link. In addition review the list of speakers at http://www.epa.gov/glo/pdfs/sacpubregistrationglo.pdf

Take a look; it may surprise you who spoke.

CARB

On Feb. 4, California Air Resources Board (CARB) staff held a webinar on its current Consumer Product Survey. Remember, the survey is due on March 2, 2015.

The Survey was released in September 2014 and is very comprehensive. Almost all categories need to be reported. You need to include sales, labels and formulas to 100%. If you have not started, you need to get moving on this survey. The better the information that is submitted, the better rulemaking we can have later on.

During the webinar, CARB staff answered the industry’s questions. CARB stated that they were willing to grant some extensions, which is big news because, up until now, CARB had said no extensions! You will need to apply for an extension and will need a good reason for it. For example, there are many formulators waiting for the responsible party to fill out the survey and forward the survey data on the formulas to them. If the responsible party does not act in a timely manner, the formulators will not have time to reply, thus the need for an extension. CARB’s website has the latest slides from the last webinar, as well as extension information:

The U.S. Dept. of Transportation (DOT) published its latest final rule, HM-215M, to maintain alignment with international standards by incorporating various amendments. These include changes to proper shipping names, hazard classes, packing groups, special provisions, packaging authorizations, air transport quantity limitations and vessel stowage requirements.

In this final rule, PHMSA is amending the Hazardous Materials Regulations (HMR) to incorporate changes from the 18th Revised Edition of the United Nations (UN) Model Regulations, Amendment 37–14 to the International Maritime Dangerous Goods (IMDG) Code, and the 2015–2016 International Civil Aviation Organization (ICAO) Technical Instructions, which became effective Jan. 1, 2015. The IMDG Code is effective Jan. 1, 2015. However, Amendment 36–12 may continue to be used until Jan. 1, 2016. Compliance with the latest changes to the HMR in Title 49, Code of Federal Regulations, Subchapter C is not required until Jan. 1, 2016.

Therefore, it is possible that a hazardous material (e.g., certain automotive safety devices) may be classified and shipped under two different proper shipping names and packing groups, although they will share a common UN identification number and hazard class.

Notable amendments

Notable amendments to the HMR in this final rule include the following:

Updating references to international regulations, including the ICAO Technical Instructions, the IMDG Code, the UN Model Regulations, the UN Manual of Tests & Criteria, the Canadian Transportation of Dangerous Goods Regulations and various technical standards.

Adopting an exception from the HMR for marine pollutants up to 5L (1.3 gal) for liquids or 5kg (11 lbs.) for solids when these materials are packaged in accordance with the general packaging requirements of §§ 173.24 and 173.24a. These exceptions are consistent with the UN Model Regulations, the IMDG Code, and the ICAO TI.

Modifying the list of marine pollutants in Appendix B to § 172.101.

Adding minimum sizes for the OVERPACK and SALVAGE markings.

Revising and adding vessel stowage codes listed in column 10B of the HMT and segregation requirements in § 176.83 consistent with the IMDG Code.

Adsorbed gases: Adopting new entries into the HMR, adding a definition, authorizing packaging and adding safety requirements, including quantity limitations and filling limits.

Harmonizing with the latest version of the ICAO TI to ensure that the information currently authorized by the HMR to be provided by means of an alternative document be included on a shipping paper for batteries transported under the provisions of § 173.185(c)(4)(v) equivalent to Section IB of ICAO TI Packing Instructions 965 and 968. PHMSA is also harmonizing with the latest version of the ICAO TI by requiring a ‘‘CARGO AIRCRAFT ONLY’’ label on packages containing small lithium metal batteries not packed in or with equipment.

Amending the HMR definition of non-bulk packaging by adding a new paragraph (4) to include bags and boxes conforming to the applicable requirements for specification packagings in subpart L of part 178 of this subchapter—if they have a maximum net mass of 400 kg (882 pounds) or less.

Effect on the aerosol industry

Although there does not appear to be many amendments that will affect the manufacture or distribution of aerosols, there is one noteworthy change to the rules that may have some impact; 49 CFR §172.102 Special Provision 362 was revised to include a new paragraph (f) that clarifies that chemicals under pressure containing components forbidden for transport on both passenger and cargo aircraft must not be transported by air. The new text of Special Provision 362 is shown below:

This entry applies to liquids, pastes or powders, pressurized with a propellant that meets the definition of a gas in § 173.115. A chemical under pressure packaged in an aerosol dispenser must be transported under UN1950. The chemical under pressure must be classed based on the hazard characteristics of the components in the propellant; the liquid; or the solid. The following provisions also apply:

a. If one of the components, which can be a pure substance or a mixture, is classed as flammable, the chemical under pressure must be classed as flammable in Division 2.1. Flammable components are flammable liquids and liquid mixtures, flammable solids and solid mixtures or flammable gases and gas mixtures meeting the following criteria:

(1) A flammable liquid is a liquid having a flashpoint of not more than 93°C (200°F);

(2) A flammable solid is a solid that meets the criteria in § 173.124 of this subchapter; or

(3) A flammable gas is a gas that meets the criteria in § 173.115 of this subchapter.

b. Gases of Division 2.3 and gases with a subsidiary risk of 5.1 must not be used as a propellant in a chemical under pressure.

c. Where the liquid or solid components are classed as Division 6.1, Packing Group II or III, or Class 8, Packing Group II or III, the chemical under pressure must be assigned a subsidiary risk of Division 6.1 or Class 8 and the appropriate identification number must be assigned. Components classed as Division 6.1, Packing Group I, or Class 8, Packing Group I, must not be offered for transportation and transported under this description.

e. A description to which special provision 170 or TP7 is assigned in Column 7 of the § 172.101 Hazardous Materials Table, and therefore requires air to be eliminated from the package vapor space by nitrogen or other means, must not be offered for transportation under this description.

f. Chemicals under pressure containing components forbidden for transport on both passenger and cargo aircraft in Columns (9A) and (9B) of the § 172.101 Hazardous Materials Table must not be transported by air.

For questions regarding the latest final rulemaking, or to obtain a copy of the final rule, contact: steve@shipmate.com or (310) 370-3600.

Hello, everyone. Last month’s Corrosion Corner provided an overview of the relationship between spray package commercial life and spray package service life. These two lifetimes can be used to determine if corrosion is too severe to market a formula-package system or slow enough that failures will not be observed by consumers before the product is depleted and packages are recycled.

This month, I’m expanding the discussion of commercial life. Commercial life is the sum of several time periods:

The time to distribute filled packages to customer warehouses

Warehouse residence time before product is on shelves

The shelf residence time prior to consumer purchase

Time for consumers to deplete the product and recycle the package

Commercial life is influenced by the economy and the strength of the competition for individual products and product families. A strong economy usually means short commercial lives. A weak or volatile economy could increase commercial life. Competitive products could also lengthen commercial lives, particularly when competition is strong.

Figure 1 graphically illustrates a generic hypothetical model for commercial life. The Y-axis is the percent of spray containers from a given batch that are depleted and recycled at a given time. The X-axis is the spray package age when it is depleted. Commercial life in Figure 1 is defined as the time after filling when 100% of the packages are depleted and recycled.

Figure 2 has two hypothetical models for commercial life extremes. The left model (curve) portrays a strong economy with weak competition. The right model portrays a weak or volatile economy and/or when there is strong competition.

There could be a single manufacturing batch (lot) for small volume products as depicted in Figure 1. Presumably, large volume products would have multiple batches throughout a calendar year, as shown in Figure 3.

The hypothetical model in Figure 3 assumes new batches are manufactured for re-purchases when 50% of the filled packages from a previous batch are depleted and recycled. The model in Figure 3 also assumes that purchase-to-depletion time and commercial life do not change or fluctuate during the year.

Most likely, actual commercial lives are more complex than the model shown in Figure 3. Indeed, actual commercial lives are most likely a complex mixture of different models like those in Figure 2, particularly when there is a week or volatile economy and/or strong competition.

Corrosion is not an issue when service life is larger than commercial life. In most situations, spray package service life is less variable than commercial life. Next month, I will continue expanding the commercial and service life discussion with more details on the factors that determine spray package service life.

We would be happy to teach our Elements of Spray Package (Aerosol Container) Corrosion short course at your R&D facility. Contact rustdr@pairodocspro.com or visit www.pairodocspro.com. Want a specific topic discussed in an issue of Corrosion Corner? Please send your suggestion/questions/comments to rustdr@pairodocspro.com. Back articles of Corrosion Corner are available from Spray. Thanks for your interest and I’ll see you in April.

The Food and Drug Administration (FDA) released an advisory warning consumers against purchasing three unregistered household insecticides imported from China.

Big Bie Pai Aerosol Insecticide, Tianshi Insect Killer and Baolilai Aerosol Insecticide all contain cypermethrin, a highly-toxic synthetic compound found in many ant and cockroach killers, which can cause ill effects in exposed humans, pets and wildlife. The issue is that these sprays were never evaluated for FDA compliance before showing up in places like popular Philippine market districts Divisoria and Quiapo.

The FDA originally advised against a number of toxic, unregistered made-in-China products finding their way into the Philippines, despite a local ban, back in 2013, fearing their infiltration into the U.S. Last August, a three-year-old boy experienced vomiting, diarrhea and abdominal pain after accidentally exposing himself to Big Bie Pai Aerosol Insecticide purchased in Divisoria, according to FDA officials.

Divisoria

“We’re appalled to witness such a brazen show of non-compliance that makes a mockery of our consumer health and product safety laws,” said Thony Dizon of the Philippine-based EcoWaste Coalition.

On January 6, two members of the Philippine House of Representatives filed Resolution 1020, warning the public against buying nine “imminently dangerous” household insecticides, eight of them sourced from China, including the three referenced by the FDA.

Regulatory officials have been advised by the FDA to conduct an inventory and seize all household pesticides lacking FDA registration.

The California Air Resources Board (CARB) has granted limited extensions to companies meeting certain conditions. The official deadline to submit information for the 2013 Consumer Products Survey is March 1.

A one month extension has been granted to formulators. The new deadline for formulation data is April 1, 2015. In addition, small businesses (defined as companies with 25 employees or fewer) have been granted an additional extension; their information is now due on July 1.

For more information, refer to the following statement from Independent Cosmetic Manufacturers and Distributors (ICMAD), released today:

The California Air Resources Board has announced an extension of the March 2, 2015 deadline to submit company product, ingredient and sales data for the 2013 Consumer Products Survey. Several trade associations, including ICMAD, had submitted requests for additional time to allow their members to complete the survey, citing the late notification to smaller companies. The Board recognized that more time may be needed to complete the reporting of 2013 data, and has made the following provisions:

Formulators: All formulators will automatically receive a 30 day extension to submit their formulation data, which extends the deadline to April 1, 2015. There is no need to send an email request.

Responsible Parties: Responsible Party requests will be handled on a case-by-case basis. Extension requests should be emailed to csmrprod@arb.ca.gov by February 27, 2015, with the subject line, “2013 Survey Additional Extension Request – Company Name (add your company name here).” In order to receive an extension, responsible parties must provide the following information:

1. When did you learn about the 2013 Survey?

2. When did you start working on the 2013 Survey?

3. When did you finish your data collection effort for the 2013 Survey?

4. Approximately how many products will you report? Labels?

5. How far along are you in entering data into the Consumer Products

Reporting Tool (CPRT)?

6. How much time are you requesting to complete the 2013 Survey?

ARB staff will notify each company with the results of their request via email.

Small Businesses: Responsible parties that are also a small business have an additional extension until July 1, 2015 to report 2013 data. CARB has defined “small business” as a company or entity with 25 or fewer employees. This includes full-time, part-time, contract and seasonal employees. Small businesses automatically receive the extension and do not need to send an email request.

In order to assist small businesses in completing the 2013 Survey, several one-hour small business specific webinars will be held on April 27, 28, and 29th. These webinars will be recorded and posted on ARB’s website for additional viewing.

]]>http://www.spraytm.com/carb-survey-update-select-extensions-granted.html/feed0Reminder: CARB Survey is due on March 1sthttp://www.spraytm.com/reminder-carb-survey-is-due-on-march-1st.html
http://www.spraytm.com/reminder-carb-survey-is-due-on-march-1st.html#commentsThu, 19 Feb 2015 21:43:56 +0000http://www.spraytm.com/?p=7493Remember, the California Air Resources Board (CARB) is conducting a mandatory 2013 survey of all commercial and consumer products. The survey is due March 1st–less than ten days from now.

From Regulatory Issues columnist Doug Raymond:
“By now you should be working on your California Air Resources Board (CARB) Consumer Product Survey. This very comprehensive survey needs to be completed by March 1, 2015. If you sold a Consumer Product into the state of California in 2013 and your product is on the CARB survey form, you are responsible to fill out the survey (it is state law, as well).

Some of the items that need to be included in this survey are products sold into California for sale in 2013, as well as all formula data, which means that 100% of the formula needs to be included in the survey. In addition, the ability to group products into a single entry has been greatly reduced. This means more entries to the survey.

If you have not started on the survey you need to begin now! Remember, the better the data that is submitted, the better volatile organic compounds (VOC) regulations we can develop.”

The Eastern Aerosol Association’s (EAA) annual Golf Outing will take place Tuesday, August 4 at picturesque Crystal Springs Resort in Hamburg, NJ. In response to several suggestions from EAA members, the Board decided to modify the regular format, expanding it to a two-day event and incorporating a day of hands-on technical workshops.

The three 90-minute workshops, being held Monday, August 3 at Crystal Springs Resort, will be designed to offer educational training and instruction from technical experts in various aspects of aerosol packaging.

Joe Franckowiak, Berry Plastics, teeing off on the 18th hole.

The first workshop will concern can formation, measurement, testing and performance, including different types of containers, sizes, shoulder styles and more. The second workshop will be all about filling, crimping and product testing, including how filling works and how propellants interact with products. Finally, the third workshop will center around gaskets and valves. A mini “Valve 101,” it will include discussion of gasket swell testing and different types of valves and gaskets and how they affect delivery.

The following day, Tuesday 8/4, the Golf Outing will go on as usual. Last year’s event included golf on the links style Wild Turkey course, closest-to-the-pin and putting contests, lunch, dinner, prizes and cocktails. The first place team, with a -11, was comprised of Brock Manner and Charlie Ortmann, Diversified CPC; and Bart Bastian and Nikko Lavey, Spray Products.

The Midwest Aerosol Association (MAA) is continuing its strategic partnership with the Schaumburg Boomers professional baseball team of the independent Frontier League for a fifth year. Included in the campaign are scoreboard advertisements raising awareness of aerosol packaging, anti-huffing messages and the famous between-inning Aerosol Can Race during every game at Schaumburg Boomers Stadium in Schaumburg, IL.

The MAA Board is giving member fillers the opportunity to sponsor the Aerosol Can Race, with their branded product’s name on an aerosol can mascot costume. Currently, the costumes depict three generic aerosol packages. The Boomers have 55 home games scheduled for the 2015 season, beginning with the home opener on May 22 and running through September.

]]>http://www.spraytm.com/midwest-aerosol-association-accepting-can-race-sponsors.html/feed0Lindal Group opens new facility in Turkeyhttp://www.spraytm.com/lindal-group-opens-new-facility-in-turkey.html
http://www.spraytm.com/lindal-group-opens-new-facility-in-turkey.html#commentsFri, 13 Feb 2015 15:17:47 +0000http://www.spraytm.com/?p=7463The LINDAL Group, a worldwide provider of aerosol packaging technology, has announced the creation of its newest facility in Turkey.

According to Francois-Xavier Gilbert, CEO, Lindal Group, work on this production and office complex, located east of Istanbul (Dilovasi – KOCAELIProvince), represents the latest milestone in the growth of this innovative 57-year old packaging solutions provider.

“This is a proud moment for all of us in the Lindal Group family,” Gilbert said. “Our latest addition will handle the manufacture of our innovative aerosol solutions, including valves, actuators and inserts and, soon, BOVs and custom molding. Further, the new plant will support regional and multinational customers, as well as contract fillers headquartered in the vibrant Turkish market and, eventually, throughout the region.”

This latest Lindal Group expansion is part of the company’s strategy for delivering profitable, sustainable growth through superior customer service. Similarly, the recent openings of Lindal’s Global Innovation Center in Briey, its new Itupeva, Brazil expansion, and recent investments in Mexican operations, are further examples of the company’s customer-first focus, Brand said.

“Our new Turkish facility will enhance supply chain efficiencies and provide superior product quality, service and support needed to help our customers meet their goals,” added Bernd Wucherpfennig, General Manager, Lindal Turkey Paketleme Ltd. Şti. “In addition, we are very happy that Uenal Varol, with his enormous experience in filling and BOV production, joined LINDAL Turkey this year.

“Our Turkish facility is a strategic addition that ensures our place in this increasingly important market, where East literally meets West,” he said.

The LINDAL Group develops and manufactures valves, actuators and spray caps for aerosol products used in pharmaceutical, cosmetics and food applications.

]]>http://www.spraytm.com/lindal-group-opens-new-facility-in-turkey.html/feed0GHS arrives in Canadahttp://www.spraytm.com/ghs-arrives-in-canada.html
http://www.spraytm.com/ghs-arrives-in-canada.html#commentsFri, 13 Feb 2015 15:07:42 +0000http://www.spraytm.com/?p=7460According to NexReg, Canada has finally implemented the Globally Harmonized System of Classification and Labelling Chemicals (GHS). On February 11th, 2015, the Government of Canada officially announced that the current WHMIS regulations have been updated to incorporate GHS. The new and improved regulation has been named WHMIS 2015.

The WHMIS 2015 regulations are in force as of February 11th, 2015 and will be introduced using a three phase transition period with completion set for December 1st, 2018. During this transition period, both old and new WHMIS will be present in the work place. However, the phases dictate when Manufacturers and Importers must comply with WHMIS 2015 compared to Distributors and Employers.

Revlon announced today that Benjamin Karsch is joining the company as Executive VP, Chief Marketing Officer, Revlon Consumer.

“In our extensive search, we wanted someone who could passionately inspire a deeper engagement with our brands, our consumers and the strategy of value creation of our company,” said Lorenzo Delpani, Revlon’s CEO. “We are excited to have found these leadership qualities in Benjy, who is an important addition toward fully realizing our vision of Love Is On and our mission to offer better beauty solutions to our consumers.”

Karsch is an expert in consumer-facing brands and packaged goods. Most recently he served as Cigna’s chief marketing officer where he was responsible for shifting their U.S. health insurance business from a B2B focus to a consumer-centric approach, re-launching their brand and building digital, mobile, marketing analytics, customer insights, and customer experience capabilities. He has experience across diverse industries, from consumer products to hospitality to healthcare, and diverse geographies, from China to Israel. In prior roles, he led global marketing at Las Vegas Sands, served Fortune 100 packaged goods clients at McKinsey & Company, and held brand management leadership roles in both the U.S. and overseas markets at Procter & Gamble and Johnson & Johnson. His command of data analytics reaches back to the Bachelor of Science in Economics that he received from the University of Pennsylvania.

]]>http://www.spraytm.com/revlon-announces-new-chief-marketing-officer.html/feed0Around the Industryhttp://www.spraytm.com/around-the-industry-2.html
http://www.spraytm.com/around-the-industry-2.html#commentsFri, 06 Feb 2015 17:26:58 +0000http://www.spraytm.com/?p=7448According to a recent study by hotel chain Hilton, 73% of U.S. travelers admit to taking home hotel toiletries, and many have found creative reasons to use them after their stay. According to Hilton, 54% of business travelers have used hotel toiletries to clean their shoes before a meeting or event, while 39% of millennials have used them to remove stains. Fifty-five percent of men admit to taking body lotion home. Nearly 20% of U.S. travelers re-purpose purloined hotel toiletries when hosting overnight guests in their home; 10% confessed that they have given away amenities as a present. Millennials, according to the survey, are significantly more likely (31%) to take hotel toiletries directly from the housekeeping cart than those 55 and older (13%).
The Irish Exporters Association (IEA) named medical device and drug delivery company Aerogen as 2014 Exporter of the Year at its Export Industry Awards held at the Dublin Convention Center. The awards recognize the achievements of companies working in the export industry. Aerogen specializes in the design, manufacture and marketing of aerosol drug delivery systems, aimed at the critical care respiratory market. Aerogen’s patented OnQ aerosol technology is an integral part of its drug delivery systems that allows drugs to be nebulized into a fine particle mist that can be absorbed through the lungs while maintaining drug integrity.

The Detroit, MI Fire Department received a donation of 5,000 fire extinguishing aerosol cans to be handed out at community meetings and during residential smoke detector installations. The donation is from Hardge Industries; the fire department says the distribution of fire extinguishing aerosol cans is part of its ongoing public safety community outreach efforts.

There are many opportunities to export aerosols and other dangerous goods to Mexico, but it requires a bit to understand the regulatory requirements for the storage, handling and transport of dangerous goods to and within Mexico.

Standards

The Mexican Secretaría de Comunicaciones y Transportes or Secretariat for Communications & Transport (SCT), roughly equivalent to the U.S. Dept. of Transportation (DOT) or Canada’s Transport Canada, is responsible for publishing and maintaining the Mexican Standards or Normas Oficiales Mexicanas (NOMs), which supplement the Reglamento para el Transporte Terrestre de Materiales y Residuos Peligrosos (Mexican Regulation for the Land Transport of Hazardous Materials & Wastes). In addition, there are other Mexican government agencies that have published standards relevant to the storage, handling and transport of chemicals and dangerous goods including Secretaría del Trabajo y Previsión Social (Secretariat of Labor & Social Welfare—the equivalent of U.S. Occupational Safety & Health Administration [OSHA] and Health Canada) and Procuraduría Federal de Protección al Ambiente (Mexican Federal Environmental Protection Agency—the equivalent of U.S. Environmental Protection Agency [EPA] and Environment Canada).

The SCT’s NOMs for the transport of dangerous goods are fairly consistent with those of older versions of the United Nations Recommendations on the Transport of Dangerous Goods (UN Model Regulations). Since the U.S. Hazardous Materials Regulations are periodically harmonized with the UN Model Regulations, the requirements of the HMR and of the Mexican NOMs are also fairly consistent. However, there are some significant differences with respect to classification and hazard communication.

These differences are being addressed by the Land Transportation Standards Hazardous Materials Working Group and through amendments and restructuring of the UN Recommendations. As a general rule, the requirements of the Mexican NOMs are four to ten years behind the latest version of the UN Recommendations. It is important to note, however, that there have been a number of recent updates to specific sections of several NOMs that make some of the Mexican rules current with contemporary standards of the U.S. DOT’s Hazardous Materials Regulations (HMR) and Canada’s Transport of Dangerous Goods (TDG) Regulations. For example, the SCT recognizes and authorizes the use of the Limited Quantity hollow diamond with black points mark for dangerous goods documents on a bill of lading as “Cantidad Limitada” or Limited Quantity. SCT also recognizes and authorizes the basic description sequence (e.g., ID number, shipping name, hazard class and division, and packing group if it applies), which is consistent with the HMR and TDG.

The most significant differences between the HMR/TDG and the SCT’s NOMs appear to be in the List of Dangerous Goods. The latest version of NOM-002-SCT (Listado de las Substancias y Materiales Peligrosos más Usualmente Transportados) was published in 2011 and does not include any items having a UN ID number greater than 3,495. In addition, a number of special provisions are not consistent between the two sets of rules and the current marine pollutant marking and excepted quantities markings are not included.

Key standards are shown in the following table:

Standard

Title

NOM-002-SCT/2011

List of Hazardous Materials Most Commonly Carried in Transport. Note: The English translation does not include the list of hazardous materials; for the actual list consult the Spanish version

NOM-003-SCT/2008

Labeling Requirements for Hazardous Materials Packaging Used for the Land Transportation of Hazardous Materials & Wastes

NOM-004-SCT/2008

Placarding Requirements for Transport Units Engaged in the Land Transportation of Hazardous Materials & Wastes

NOM-005-SCT/2008

Emergency Response Information for the Land Transportation of Hazardous Materials & Wastes

NOM-006-SCT2/2011

Requirements for the Daily Visual Inspection of Transport Units Involved in the Transportation of Hazardous Materials & Wastes

With respect to packaging, marking, labeling and documentation, the requirements of the SCT’s NOM-003-SCT/2008 and NOM-043-SCT/2003 are essentially identical to those of the HMR and TDG. Packaging must conform to the UN Performance Oriented Specification Packaging standards for other than limited quantities. Packages must also be properly marked and labeled with the proper shipping name, UN identification number and corresponding primary and subsidiary risk labels, if applicable. Although it does not specify the language to be used for the marking of the proper shipping name, it is implied that the language must be in Spanish. NOM-043-SCT/2003 does require that the dangerous goods declaration be available in Spanish. The Dangerous Goods Declaration specified in NOM-043-SCT/2003 is identical to the Multimodal Dangerous Goods form specified in the UN Recommendations on the Transport of Dangerous Goods, except that it is in Spanish.

The SCT does recognize and authorize dual-language marking and documentation. Therefore, it is recommended that packages be marked in both English and Spanish, and that copies of dangerous goods declarations be made available in both English and Spanish.

It is important to note that shipments to Mexico offered for transport by air must be marked and documented in English, but dual language marking and documentation is acceptable.

Additional Documentation

In addition to the required bill of lading, shipments to Mexico must, in most cases, be accompanied by the following documents:

Commercial Invoice

Freight Invoice

Inward Cargo Manifest

Shipper’s Letter of Instruction

NAFTA Certificate of Origin

Packing Slip

Shipper’s Export Declaration

Pedimento (Mexico’s Customs Entry Form); and

Safety Data Sheet

The Safety Data Sheet must be available in Spanish and conform to either NOM-018-STPS/2000 or NMX-R-019-SCFI/2011. Mexico was the first country in North America to adopt the Globally Harmonized System of Classification & Labeling of Chemicals (GHS) standard for Safety Data Sheets (Sistema Armonizado de Clasificación y Comunicación de Peligros de los Productos Químicos). Safety Data Sheets conforming to the older NOM-018-STPS/2000 standard require 12 sections, while those conforming to NMX-R-019-SCFI/2011 require 16 sections, which is consistent with Revision Three of the GHS standard.

In recognition of the pending implementation of GHS requirements in the U.S., it is strongly recommended that Safety Data Sheets be made available in the GHS format, but translated into Spanish for acceptance by the Mexican regulatory authorities and to facilitate transport within Mexico.

For questions regarding the transport of dangerous goods to and within Mexico, its implementation or impact, or to obtain a copy of any of the Normas Oficiales Mexicanas, contact steve@shipmate.com or (310) 370-3600.

]]>http://www.spraytm.com/transport-of-dangerous-goods-into-and-within-mexico.html/feed0Commercial life vs. Service lifehttp://www.spraytm.com/commercial-life-vs-service-life.html
http://www.spraytm.com/commercial-life-vs-service-life.html#commentsFri, 06 Feb 2015 17:15:47 +0000http://www.spraytm.com/?p=7437
Hello, everyone. Last month I discussed several corrosion and statistical technical terms that are relevant to spray package corrosion. This month I’ll expand that discussion by focusing on the relationship between commercial life and service life. These two lives can be used to determine if corrosion is too severe to market a formula-package system or slow enough that failures will not be observed by consumers before the product is exhausted from the package and it is recycled.

My original intention for this article was to discuss the relationship between commercial life and service life. While writing, I realized I also need to provide a more detailed discussion about what factors affect the magnitude of both commercial and service lives. Consequently, the discussion this month will cover the relationship between the two lives and the next one or two issuess will provide more detailed discussions on the factors that determine them. Let’s review the definitions of each.

Service life

Service life is the time when the package performs as specified. In other words, the package sprays and does not leak. Service life is determined by the type of package materials, package metal surface treatment (e.g., coated or uncoated), the physical form of your formula (e.g., emulsion or single phase) and the chemical composition of your formula. Service life is estimated from corrosion data from either a long-term storage test or electrochemical corrosion testing.

Commercial life

Commercial life is the time after filling that it takes for consumers to completely use the product and recycle the package. Commercial life is a function of the economy.

Figure 1 graphically illustrates a generic commercial life profile for containers filled during a given manufacturing batch (lot). Figure 1 has two curves because an actual commercial profile is affected by the economy. A growing economy normally decreases commercial life (short filling-to-recycle times) and a stagnant or declining economy normally increases commercial life (long filling-to-recycle times).

The Y-axis is the fraction of the containers from the batch that are empty (completely consumed) and recycled after a given time. The X-axis is the time after batch filling is completed. The time axis would be in days and is left blank to keep the curves generic.

The two vertical dashed lines in Figure 1 illustrate that the filling-to-recycle time ranges between approximately 2.5 and 3.25 time-units; one for a hypothetical growing economy and the other for a hypothetical stagnant or declining economy, respectively.

Figure 1 also illustrates that commercial life could be defined in several ways. For example, commercial life could be defined as the time when 90% or 95% of the filled containers are exhausted and recycled instead of 100%. It has been our experience that each type of formula-package system has a different commercial life range.

Figure 2 illustrates a situation where the estimated service life is greater than the commercial life. The second commercial curve is omitted for simplicity.

In this example the corrosion is very slow and empty packages are in the recycle stream long before container failures are expected to begin (failure is leaking or non-spraying). Thus, package corrosion in this example does not present a problem, as long as the economy doesn’t cause the commercial life to become longer than the service life.

Figure 3 illustrates a situation where the commercial life is longer than the service life. This type of situation typically occurs when the corrosion rate is large. The vertical dashed line in Figure 3 shows that approximately 70% of the containers from a given manufacturing batch are exhausted and recycled after approximately 1.25 time units. In other words, approximately 30% of the filled containers at this time are still full and a fraction of the consumers would probably have packages that either leak or do not spray. The magnitude of the fraction could be low or high.

The corrosion illustrated in Figure 3 should be addressed before the product-package system is ready for introduction into the marketplace. The situation in Figure 3 also illustrates how a large difference between service life and commercial life is desirable to avoid unwanted,surprise failures caused by package variability, product chemical composition variability or economic fluctuations.

Next month, I’ll continue this discussion with more detail about the factors that determine the magnitudes of commercial life and service life.

We would be happy to teach our Elements of Spray Package (Aerosol Container) Corrosion short course at your R&D facility. Contact rustdr@pairodocspro.com or visit www.pairodocspro.com. Want a specific topic discussed in an issue of Corrosion Corner? Please send your suggestion/questions/comments to rustdr@pairodocspro.com. Back articles of Corrosion Corner are available from Spray. Thanks for your interest and I’ll see you in March.

By now you should be working on your California Air Resources Board (CARB) Consumer Product Survey. This very comprehensive survey needs to be completed by March 1, 2015. Some of the items that need to be included in this survey are products sold into California for sale in California in 2013, as well as all formula data, which means that 100% of the formula needs to be included in the survey. In addition, the ability to group products into a single entry has been greatly reduced. This means more entries to the survey. If you have not started on the survey you need to begin soon! Remember, the better the data that is submitted, the better rules we can develop.

On Feb. 4, CARB staff plans to have a webinar from 10am–1pm Pacific Time to respond to any questions to the 2013 Consumer & Commercial Products Survey. Questions on data upload, upload portal and reporting tools are welcome. Registration for the webinar is available here.

Research studies on Low Vapor Pressure (LVP) compounds are currently being funded by CARB to determine if they contribute significantly to ground level ozone. Remember, LVP compounds have been the avenues for compliance with the strict volatile organic compound (VOC) limits that CARB has developed since the mid to late 1990s. LVP compounds are not counted toward the total VOC content for compliance with VOC limits. Any change to the LVP compound definition that would change or restrict the use of LVP compounds could mean that the current VOC limits are not technologically feasible as required by California law.

Currently there are ongoing studies at the University of California, Riverside and the University of California, Davis. These studies will likely be finished in 2016. Industry needs to monitor these studies and provide feedback to CARB on this issue. Stay tuned for updates. As stated above, any change to the LVP definition will have a substantial impact on current formulas.

VOC limits

New Aerosol Coating product limits became effective for the Specialty Coating Categories (B) on 1/1/2015. A VOC limit for Multi-Purpose Solvent and Paint Thinner Aerosol will become effective 1/1/2016; this new VOC limit is 10% by weight.

On 1/1/2017, Mist Spray Adhesive will have the VOC limit reduced from 65% to 30%—this is a significant drop. The Web Spray Adhesives VOC limit is reduced from 55% to 40%—another big drop. Companies with these products need to begin reformulating now to determine if these VOC limits are technologically feasible; if the reformulations are not possible, then CARB needs to be notified.

Also, on 1/1/2017, all the new Aerosol General Coating limits and Specialty Coatings (A) VOC limits become effective. Some of the VOC limit changes are significant. Companies making these products should review these limits and begin work on reformulation.

Green Chemistry

The Dept. of Toxic Substance Control (DTSC) will likely begin rulemaking on its initial list of Priority Products and Chemicals of Concern. Remember, it was in March 2014 when DTSC first announced the following products and chemicals of concern:

Alain D’Haese, Secretary General of the European Aerosol Association (left) greets Grant Coupland, Chairman of the British Aerosol Manufacturers’Association, as well as Marketing & Innovation Director for Colep at the Colep booth during the 9th Aerosol & Dispensing Forum held in Paris this week.

The annual National Science Teachers Association (NSTA) Conference takes place in Chicago, IL, March 12-14. Each year, the conference offers an opportunity for Consumer Aerosol products Council (CAPCO) to reach out to teachers and others to help educate consumers about the benefits of aerosols and their recyclability. You can help by providing samples to give away at the CAPCO booth and/or volunteering to staff the booth for a day.

Product Donations:
Distributing sample products as giveaways is a great way to draw traffic to the booth. In past years, we have given away 1,500-3,000 samples during the three-day expo. We’ve given out a variety of items, including Sprayway Glass Cleaner, WD-40 sample sized lubricants, KIK Corporation’s assorted travel sized personal care products, Faultless Starch’s Magic Wrinkle Remover, Chase assorted products and many more. Once again, we thank donors from past years!

If you have products to donate (any amount will help drive traffic to booth!), please reach out to hvanderband@aerosolproducts.org for details on when and where to ship them. We prefer sample-sized products, as they are more convenient for travel.

Volunteers:

The conference will take place at McCormick Place West * 2301 South Lake Shore Drive * Chicago IL 60616, and the exhibit schedule is as follows:

Thursday, March 12, 2015 (Need 2 Volunteers)

11:00 AM-6:00 PM

Friday, March 13, 2015 (Need 2 Volunteers)

9:00 AM-5:00 PM

Saturday, March 14, 2015 (Need 2 Volunteers)

9:00 AM-3:00 PM

We have found that it is best to have three people at the booth each day (2 volunteers, plus Hillary). We generally ask that each volunteer commit to at least one full day.

Please let Hillary VanderBand know if you or someone at your company is able to volunteer, and we’ll send more information.CONTACT: hvanderband@aerosolproducts.org

The innovation is the result of a partnership between APPE and US-based Power Container Corp, a privately-owned developer and manufacturer of airless dispensing systems. SprayPET Reveal is the combination of APPE’s transparent SprayPET container with Power Container Corp’s Power Pouch dispensing system, the next generation bag-on-valve, which is also transparent.

A European-exclusive agreement between both companies means that SprayPET is the only plastic aerosol container that can be used with Power Pouch.

Bag-on-valve pouches, usually opaque silver in color, are flexible multilayer laminated bags, made from layers of nylon, polyethylene and aluminum. Power Pouch is manufactured from single-layer PET, yet retains all of the benefits of bag-on-valve technology. Unlike multilayer laminated pouches, Power Pouch is a seamless bag that provides inherent strength.
Structurally and chemically robust, the SprayPET Reveal system operates with standard actuators, is environmentally friendly and easy to recycle through normal curbside collection.

The container and pouch can be clear or coloured, and both are fully food-approved for food-based applications. SprayPET containers have the ability to be printed or fully or part sleeved.

APPE’s SprayPET Category Director, Murdoch Crawford, says: “The SprayPET Reveal system represents a world-first as a fully transparent bag-on-valve aerosol solution. It offers all the benefits of a standard bag-on-valve aerosol, yet also provides fillers and retailers a genuine opportunity to create real on-shelf differentiation for the first time and the ability to showcase the product to maximum advantage. For consumers, not only can the product be sprayed at any angle, there is the added benefit of being able to accurately predict the need for a replacement as the remaining contents can be seen.”

Power Container’s Piet Molemans says, “We are delighted to be working with APPE in Europe. Power Pouch complements the SprayPET container perfectly and we are confident that the SprayPET Reveal system will be very successful in the retail environment.”

Ashland announced the commercial launch of its new Advantage 4910 polymer with a trade press luncheon and tour of the company’s research and development facility on Wednesday, Jan. 16 in Bridgewater, NJ.

The polymer, a hair fixative known for providing long-lasting hold, stiffness and resistance to humidity, gravity and vibration, is included in more hairspray products than any other polymer, according to Ashland, and the technology has existed for at least 30 years. It is now available from Ashland Specialty Ingredients’ for the first time, substantially expanding the company’s dynamic portfolio of solutions for manufacturers of hairspray products–especially given its ability to be used in conjunction with a number of other polymers.

The assortment of possibilities was put on display in Ashland’s Consumer Science Lab Wednesday afternoon. Five models sported five different hairstyles, while an Ashland resident cosmetologist explained the various formulations used in each of the five sprays–all including the Advantage 4910 polymer. Ingredients used with Advantage 4910 included the Aquaflex FX-64 polymer, Advantage LC A/S polymer and PVP/VA copolymers.

In the Materials Science Lab, Ashland exhibited some of its Dynamic Hairspray Analysis procedures, examining attributes like flexibility, elasticity, stiffness, plasticity and resistance to factors like differing temperatures, humidity, gravity and vibration. The idea was to study the impact of everyday stress on treated hair fibers.

Ashland is only the second manufacturer to supply the octycrylamide/acrylatesbutylaminoethyl methacrylate copolymer, according to the company. Advantage 4910 can be used in both aerosol (including BOV) and non-aerosol product formulations.

]]>http://www.spraytm.com/ashland-introduces-new-advantage-4910-polymer.html/feed0Ball announces expansion at UK aerosol planthttp://www.spraytm.com/ball-announces-expansion-at-uk-aerosol-plant.html
http://www.spraytm.com/ball-announces-expansion-at-uk-aerosol-plant.html#commentsWed, 14 Jan 2015 16:51:30 +0000http://www.spraytm.com/?p=7343Ball Corporation announced plans to add a new high-speed line in its Devizes, UK, impact extruded aerosol can manufacturing plant. The additional line, which will allow the company to meet growing customer and European market demand, will begin production during the fourth quarter of 2015.

“As a leader in the production of metal aerosol packaging, Ball is continually working to optimize its global and regional manufacturing footprint to meet our customers’ needs,” said Michael W. Feldser, Senior VP, Ball Corporation, and COO, Global Metal Food & Household Products Packaging. “This expansion will allow us to continue meeting demand, while broadening and deepening the development and commercialization of market-leading innovations, such as our light weight can with recycled content, new shapes and formats, compressed aerosol cans, as well as a diverse range of impactful printing technologies.”

]]>http://www.spraytm.com/ball-announces-expansion-at-uk-aerosol-plant.html/feed0DuPont spins off multiple brands…http://www.spraytm.com/dupont-spins-off-several-brands.html
http://www.spraytm.com/dupont-spins-off-several-brands.html#commentsFri, 09 Jan 2015 17:06:01 +0000http://www.spraytm.com/?p=7329DuPont Fluorochemicals recently announced that it has sold the global marketing, sales and distribution rights for its Dymel Pharmaceutical Propellants businesses to companies more strategically aligned with this unique market segment. This DuPont Fluorochemicals business is part of the Performance Chemicals segment that DuPont anticipates separating by mid-2015. The sale was specifically limited to its regulated pharmaceutical products, HFC-134a/P and HFC-227ea/P, and excluded all merchant or industrial grades of these products. The sale also excluded manufacturing assets.

According to the company, DuPont Fluorochemicals is making this move to enable a stronger focus on developing and commercializing the company’s new family of products based on hydrofluoroolefins (HFOs), which have very low global warming potential compared to the products they are designed to replace.

After completing the sale transition, DuPont will also exit use of the Dymel brand and will pursue plans for rebranding its HFC-152a and dimethylether propellant products consistent with commercialization of the company’s new family of low global warming products.

Additionally, DuPont intends to spin off a new performance chemical company, ranked among the largest in the U.S., with the new name of Chemours, a nod to DuPont’s full name, E. I. du Pont de Nemours & Co. The firm will occupy a building in Wilmington, DE that DuPont, after more than 100 years, is vacating. DuPont shareholders will be entitled to shares in Chemours.

Chemours’s biggest business, the white pigment titanium dioxide, makes up 46% of sales. Fluoroproducts account for 36% of sales. The rest of Chemours’s businesses are in sodium cyanide, sulfuric acid, aniline, and other chemicals.

DuPont announced its intention to spin off the performance chemicals business in 2013 as part of a plan to focus on biotechnology, agriculture, electronic materials, and other endeavors that are high growth and technology intensive. DuPont will also exit the city of Wilmington, where it has been headquartered for more than a century. The company is moving its base to Chestnut Run, DE where it opened a 220,000-sq-ft office building in 2012.

]]>http://www.spraytm.com/dupont-spins-off-several-brands.html/feed0Honeywell starts full-scale production of HFO-1234zehttp://www.spraytm.com/honeywell-starts-full-scale-production-of-hfo-1234ze.html
http://www.spraytm.com/honeywell-starts-full-scale-production-of-hfo-1234ze.html#commentsTue, 06 Jan 2015 18:10:47 +0000http://www.spraytm.com/?p=7327Honeywellannounced that it has started full-scale commercial production of a low-global-warming-potential (GWP) material used as an aerosol propellant, insulating agent and refrigerant.

The material, known by the industry designation HFO-1234ze and marketed by Honeywell under its Solstice® line of low-global-warming materials, is being produced at the Honeywell Fluorine Products facility in Baton Rouge, La.

“Honeywell’s Baton Rouge production facility is ready to serve customers around the world with this innovative material, which has an ultra-low GWP of less than 1,” said Ken Gayer, vice president and general manager of Honeywell’s Fluorine Products business. “We are seeing increasing demand for our entire Solstice line of low GWP materials, and this new product has already been adopted by a range of customers globally.”

Honeywell’s Baton Rouge facility was built in 1945 and continues to serve as one of Honeywell’s main manufacturing sites for its Performance Materials and Technologies business. The site employs more than 200 people.

Louisiana Governor Bobby Jindal said, “Honeywell helps support hundreds of jobs in our state, and we’re proud the company is expanding in Baton Rouge with a brand new product line. This project is a good example of how Louisiana’s outstanding business climate is convincing companies like Honeywell to reinvest in our state, retain great existing jobs and create additional new career opportunities for our people.”

In September 2014, at an event sponsored by the White House, Honeywell announced that it will increase production of its low GWP refrigerants, insulation materials, aerosols and solvents, and, prior to 2020, will drive a 50 percent reduction in its annual production of high GWP hydrofluorocarbons (HFCs) on a CO2 equivalent basis. The company projects that use of its low GWP Solstice materials to replace HFCs will eliminate more than 350 million metric tons in CO2 equivalents by 2025, equivalent to removing 70 million cars from the road for one year.

HFO-1234ze is a next-generationmaterial that is non-ozone-depleting,non-flammable per ASTM E681 and ISO 10156:2010 testing, and has a low-global-warming-potential of less than 1. It is also not a volatile organic compound (VOC), as determined by the U.S. Environmental Protection Agency (EPA) and the California Air Resource Board (CARB). HFO-1234ze is considered a preferred replacement for both HFC-134a (which has GWP of 1,300) and HFC-152a (which is flammable and has a GWP of 138) in aerosol applications and thermal insulating foams, including extruded polystyrene board and polyurethane foams. It is also being considered to replace HFC-134a for large stationary and commercial refrigeration applications and, compared to other low GWP refrigerant options, Honeywell’s HFO-1234ze provides energy efficiency benefits.

HFO-1234ze is part of Honeywell’s line of Solstice hydrofluoro-olefin (HFO) products that have extremely low global warming potentials – either equal to or less than carbon dioxide – and that are safe, available today and capable of making a significant positive environmental impact. Honeywell’s Solstice HFOs are alternatives to high GWP HFCs and are energy-efficient, safe to use, non-ozone-depleting and have a minimal global warming profile.

Honeywell’s Solstice line of HFOs include Solstice yf for automobile air conditioning, Solstice Propellant for aerosol applications, Solstice Liquid Blowing Agent and Gas Blowing Agent for foam applications, and Solstice Performance Fluid for use as an industrial solvent. Each of these products has been approved under the EPA’s Significant New Alternatives Policy (SNAP) program.

]]>http://www.spraytm.com/honeywell-starts-full-scale-production-of-hfo-1234ze.html/feed0January Feature: The regulatory arena…http://www.spraytm.com/january-feature-the-regulatory-arena.html
http://www.spraytm.com/january-feature-the-regulatory-arena.html#commentsFri, 02 Jan 2015 16:27:05 +0000http://www.spraytm.com/?p=7299
As we usher in 2015, many questions arise as to what the regulatory arena will look like. In an effort to bring readers a variety of perspectives, SPRAY surveyed regulatory experts and researched various sources to bring together a comprehensive look at what lies ahead in the aerosol and related industries.

Aerosol and other consumer products will face a number of challenges at the state, federal and international levels in 2015, many carried over from 2014.

At the state level, the California Dept. of Toxic Substances Control (DTSC) will continue implementing the Safer Consumer Products Regulation. The department has released a work plan identifying product categories of interest and intends to name five to ten products each year, in addition to the three priority products that were announced in 2014.

Another carry-over from 2014 action in California is the Consumer & Commercial Products Survey, because companies will continue to dedicate significant time and resources in responding to this activity. The scope of the survey is unprecedented both in terms of the expanded number of products and the scope of data being required. Many companies will be challenged to meet the March 2, 2015 deadline for completing the initial year’s reporting of 2013 products because they will also need to begin the second-year reporting of 2014 products by the end of this year.

A new action in 2015 will be the updated ozone State Implementation Plan. The South Coast Air Quality Management District (SCAQMD) and the California Air Resources Board (CARB) will begin developing the plan for submission to the U.S. Environmental Protection Agency (EPA) in 2016. The plan will contain new commitments for volatile organic compounds (VOC) reductions from consumer products.

Data gleaned from the CARB survey will help form the extent of the commitments, as will the results of ongoing research projects conducted by CARB and the industry on the impacts of Low Vapor Pressure (LVP) and VOCs on ozone and particulate matter. For example, the survey covers over 500 categories of consumer products, some of which have never been surveyed before.

FederalAt the federal level, the EPA will finalize its rule under the Significant New Alternatives Policy (SNAP) Program to eliminate many current uses of the aerosol propellant HFC-134a. The CSPA filed extensive comments on the August 2014 proposal, seeking a few more allowed uses and additional time beyond the January 2016 proposed phase-out deadline.

The EPA will continue implementing its Work Plan Chemical Program to evaluate the safety of specific chemical uses under the existing Toxic Substances Control Act (TSCA), as efforts continue to modernize it.

The U.S. Occupational Safety & Health Administration (OSHA) will continue implementing its 2012 Hazard Communications Rule, with critical 2015 deadlines for revised labeling and Safety Data Sheets. The rule implements the Globally Harmonized System of Classification & Labeling (GHS) in the U.S. workplace.

The U.S. Dept. of Transportation (DOT) is planning to issue a major proposed transport rule that would be the most extensive update in many years.

Retailers as regulatorsNon-traditional regulators will continue to emerge in 2015; retailers are establishing new requirements for consumer products. One common theme so far is the desire for ingredient communication. Wal-Mart will require certain consumable products it sells to have ingredients communicated on a website starting January 2015, and Target will base 20% of its product sustainability score on ingredient disclosure. The CSPA Consumer Product Ingredients Dictionary can assist companies in compliance with these retailers’ policies. The CSPA has been communicating with various retailers to assure that their sustainability initiatives result in improvements to our member companies’ products, rather than conflicting standards that deter innovation.

Aerosol recyclingThe CSPA also continues efforts to encourage increased recycling of used aerosol products consistent with good product stewardship and numerous retailers’ sustainability goals. All empty aerosol containers are fully recyclable and rates continue to climb. A caution, however, is the Federal Trade Commission (FTC) interpretation that the phrase “please recycle when empty” is an environmental marketing claim. Therefore, data is needed to show a substantial majority of consumers have access to aerosol recycling before companies can place such a claim on their product labels.

The CSPA has already partnered with the Steel Recycling Institute to obtain the necessary data for steel aerosol containers. The goal for 2015 is to obtain the additional data for aluminum aerosol containers to show their recyclability.

NFPAAs a final challenge, the National Fire Protection Association (NFPA) recently issued its 2015 edition of NFPA Code 30B, which covers the manufacturing, warehouse storage and retail display of aerosol products. The update is extensive. It will be phased into use by local and state fire and building officials in 2015. The CSPA worked to ensure that the new fire code requirements are science-based and provide cost-effective protection against aerosol fire risks.

It’s amazing what an impact one building can have on businesses across the globe. The California Dept. of Environmental Protection (Cal EPA) headquarters in Sacramento, CA, is one such building. Cal EPA is the home to the Dept. of Toxic Substances Control (DTSC), CalRecycle, California Air Resources Board (CARB) and the Office of Environmental Health Hazard Assessment (OEHHA), to name a few. These departments are actively pursuing programs which promise to have major impacts on business. Most readers are likely familiar with activities at CARB, so I will focus on the other three departments.

The Safer Consumer Products program, run by DTSC, released its first set of three priority products/chemical combinations in March 2014. The first three priority products were:

DTSC plans to place these priority products into regulation in early 2015. Once they are placed into regulations, manufacturers of these priority products will have approximately two years to perform an Alternative Analysis (AA) report. Based on the AA, DTSC may pursue a number of regulatory responses ranging from product labeling to sales prohibition.

DTSC also released a draft work plan laying out potential priority product listings for the next three years. This report included six broad product categories they would be looking at to determine future priority products. One product category is building products, which includes paints, primers and graffiti removers. The draft plan is expected to be finalized in early 2015 and the next set of priority products will be identified at that point.

For the past two years, CalRecycle has been developing a plan to reach its required 75% recycling goal. A workshop was held in November 2014 to continue its discussions of how California will meet its goal through recycling, composting or source reduction of solid waste by 2020. CalRecycle stated in their background paper that they intend to focus on paper and plastic products and its preference to implement mandatory Extended Producer Responsibility (EPR) programs (a strategy designed to promote the integration of environmental costs associated with goods throughout their life cycles into the market price of the products) to meet the aggressive requirement of 75%. CalRecycle did say they currently do not have the authority to implement mandatory programs, which should lead to legislation in 2015 designated to give them that power.

OEHHA is pursuing changes to the Prop 65 regulations that require businesses to list warnings on their products if they contain chemicals known to cause cancer or birth defects or other reproductive harm. The department has shared draft regulations for stakeholders to review and share feedback. These draft regulations included a requirement to identify up to 12 specific chemicals in a warning, foreign language requirements for warnings and changes to the safe harbor provisions. The formal regulation process is expected to begin in early 2015.

Raymond

Doug Raymond, Raymond Regulatory Resources (3R), LLC

I have been accused of being a bearer of bad news; so as to not to disappoint anyone, here is my outlook for 2015. Two areas of regulation I see ramping up are volatile organic compounds (VOC) and Green Chemistry. The U.S. Environmental Protection Agency (EPA) is likely to pass a new, stricter ozone standard early in 2015. This means that numerous states will be trying to find more emission reductions. Therefore, more states are likely to follow the Ozone Transport Commission’s (OTC) and California Air Resources Board’s (CARB) lead on Consumer Product regulations. Likewise, CARB and OTC will then need to find more emission reductions. CARB will likely start new Consumer Product rule developments in late 2015 and early 2016.

Regarding Green Chemistry regulations, California has taken the lead on these types of regulations calling them the Safer Consumer Products regulations. I believe most states will hold off on these types of regulations until they see how California handles its current regulation. This current draft regulation will likely take a year to finalize, which means very late in 2015. Green Chemistry-type regulations are new for the industry and affect how products are formulated. Currently, California has a three-year plan that includes a majority of our [aerosol] products. Therefore, for the foreseeable future, Green Chemistry will be another regulation that the industry will need to deal with on an ongoing basis. This adds another dimension to the formulation of Consumer Products.

Another extremely important issue involves trying to comply with the Global Harmonization System (GHS) by the 2015 deadlines. Likewise, the Significant New Alternatives Policy (SNAP) amendments will be finalized in 2015 and we will have to deal with that regulation as well.

Sunscreens are an important over-the-counter (OTC) drug used to protect individuals from the damaging effects of the sun. Sunscreen sprays are a popular means of administering sunscreens on children, especially because we know that one bad sunburn in childhood doubles the risk of developing skin cancer later in life.

The U.S. Food & Drug Administration (FDA) is in the process of developing regulations addressing the use of spray sunscreens. In 2011, FDA published an advance notice of proposed rulemaking (ANPR) acknowledging sprays as an appropriate sunscreen dosage form and requested additional data to support their effectiveness and safety, as well as comments on potential changes in labeling of sunscreen sprays (e.g., hold container four to six inches from the skin to apply; do not spray directly into face; spray on hands then apply to face; do not apply in windy conditions; use in a well-ventilated area).

Myers

PCPC provided data and information supporting the efficacy and safety of sunscreen sprays, and supported FDA’s proposed labeling changes. In addition, PCPC has worked to scale back the scope of a consumer product survey being conducted by the California Air Resources Board (CARB), which requires companies to report formulations and sales data over a three-year period in an effort to develop a baseline for volatile organic compound (VOC) emissions in the California marketplace. Sunscreens, and other OTC drugs, are included within the scope of the survey. Although the survey continues to be challenging for reporting companies, it is far less onerous than originally proposed thanks to an engaged business community.

Likewise, PCPC continues to focus on challenges presented by California’s Proposition 65, which lists chemicals that have been identified by an authoritative body as carcinogenic or reproductive toxicants. In 2012, titanium dioxide (TiO2), an important sunscreen ingredient, was listed as a carcinogen. After many rounds of intense negotiations with CARB, we were successfully able to ensure that certain “qualifiers” were included in the Prop 65 listing, limiting TiO2 to only that which is airborne, respirable and unbound.

In 2015, PCPC will work with the FDA to make progress on advancing the ANPR towards finalization of regulations on sunscreen spray dosage forms; help companies as they seek to comply with the onerous CARB survey; and take steps to ensure that ingredients important to sunscreen formulations—and other personal care product formulations—are not listed to Prop 65, or if they are, to ensure an appropriate “safe harbor” level is established.

In California, the amendments to the aerosol coatings reactivity regulation have become final and aerosol coatings manufacturers must comply with the first deadline of Jan. 1, 2015 for products in Specialty Category B along with general labeling requirements for all categories. In addition, since the compliance verification issues for aerosol coatings have been addressed in these amendments, the industry should expect renewed and aggressive enforcement efforts. Many of the category definitions have been modified and the “restrictive limit” requirement will be aggressively reviewed by the California Air Resources Board’s (CARB) Enforcement Division.

Until now, the aerosol coatings industry has enjoyed uniform standards as the U.S. Environmental Protection Agency (EPA) agreed to adopt the CARB standards in 2008. With the recent amendments, this uniformity has disappeared and the industry must comply with a California rule and an EPA rule that have different standards, definitions, categories and, most importantly, reactivity values for calculating compliance.

In the global marketplace, it is difficult to predict the “regulatory future” for aerosol coatings. To date, efforts to convince the EPA to expedite changes to its rule have fallen on deaf ears. Accomplishing this will require a long term effort. This leads to the question of how other governmental bodies will react to CARB’s more stringent standards. Because CARB amendments have eliminated the consistent and uniform standards for aerosol coatings, and it will likely be years before EPA initiates a rulemaking to address this disparity, it leaves open the possibility that state agencies may again revisit the aerosol coatings for potential rulemaking— especially if the ozone standard is further reduced—placing more pressure on the states to find emission reductions.

A few years ago, ACA and the Canadian Paint & Coatings Association convinced Environment Canada to forgo any regulatory action for aerosol coatings specifically because CARB was in the process of a rulemaking. Consequently, Environment Canada may be considering its “regulatory options” for this source category.

Given all these considerations, the regulatory environment for aerosol coatings will likely include enhanced enforcement from California and the potential for further regulatory activity at the EPA, potentially some state agencies and Canada.

Moffatt

Mike Moffatt, PhD, Director of Communications, Nexreg Compliance Inc.

The big regulatory battle in North America (and around the world) in 2015 and beyond will be concern the issue of ingredient disclosure. The Canadians have followed the lead of countries around the world with the implementation of the Globally Harmonized System of Classification & Labeling of Chemicals (GHS), removing the disclosure exemption for flavors and fragrances. Companies who wish to keep this information secret will have to apply for trade secret status at considerable expense. For products that are in dozens of markets, the costs rise exponentially as trade secret status must be claimed in every jurisdiction.

Due to the rising costs of preventing ingredient disclosure and increased demand from consumers, companies may decide that it is simply cheaper and easier to release this information. Expect to see more companies follow the lead of Clorox and disclose the particular fragrances in each of their products. As more large firms in the chemical industry go down that path, legislators will feel more comfortable requiring complete ingredient disclosure, particularly for consumer chemicals. Do not be surprised, when both the U.S. Consumer Product Safety Commission (CPSC) and the Canadian Consumer Chemicals & Containers Regulations (CCCR) consumer chemical regulations are updated (which will likely happen before the end of the decade), that the rules around ingredient disclosure are far less forgiving than they are now.

Troutman

Douglas Troutman, VP & General Counsel, Government Affairs, The American Cleaning Institute (ACI)

Setting the Record Straight on Minnesota’s Triclosan Debate

During the public policy debate in Minnesota over efforts to ban the antibacterial ingredient triclosan, the group Friends of the Mississippi River (FMR) pushed for this ban in the face of a great deal of information showing triclosan to be a safe and effective ingredient.

The group’s post-mortem (as posted on its website by FMR’s Trevor Russell) is as misleading as the information and arguments they used to get the law that passed. This law will effectively restrict consumer choice of antibacterial soaps and washes with triclosan as of January 1, 2017.

FMR claims that they worked with “the soap industry” to “develop a negotiated compromise” leading to legislative language that narrowed a ban to “include just consumer cleaning products used for hand and body cleansing.” FMR has the facts wrong.

Let the record be clear: the American Cleaning Institute opposed the legislation that became the enacted law on behalf of its interested member companies. ACI was in no way involved in this so-called compromise. No one here ever heard from Mr. Russell.

As we testified in the legislature and communicated to Minnesota Gov. Mark Dayton, triclosan is the most reviewed and researched active ingredient used in antibacterial soaps and body washes. Manufacturers are providing real-world scientific data and information that demonstrates what we already know: antibacterial soaps with triclosan are safe and effective.

While triclosan has been found in trace amounts in sediments in aquatic environments, there is no evidence of significant risk to humans or the environment. Research has consistently shown that triclosan and its breakdown products do not pose a risk to aquatic or terrestrial environments, nor do they pose a threat of accumulation in drinking water or food.

Use of triclosan in antibacterial soaps is regulated by the U.S. Food & Drug Administration (FDA), who has proposed new rules governing antibacterial soaps and their ingredients and is in the midst of an extensive public comment period on these proposals. Yet the Minnesota legislative ban on triclosan ignores this reality.

Instead of letting federal regulators do their job, the law would take safe, effective and beneficial products off the shelves of Minnesota grocery, convenience and drug stores.

As there will be further public policy discussions over regulating antibacterial soaps, the ACI and our members remain committed to advocacy based on valid, real-world science and solid data.

We ask FMR to refrain from distorting the facts about antibacterial product safety and how they characterize how the legislative debate transpired in Minnesota.

DeLeo

Paul DeLeo, Associate VP of Environmental Safety, ACI

Triclosan & pregnancyAnalysis of research showing trace elements of antibacterial ingredients in pregnant women and fetuses is distorting the safety profile of the materials, which have been extensively researched and reviewed for decades. The research in question was presented at the American Chemical Society national meeting and reported that trace elements of the antibacterial ingredients triclosan and triclocarban were detected in the urine of pregnant women, as well as some umbilical cord blood samples.

Some of the researchers’ public comments—as well as news media headlines about the research—may mislead the public about the ingredients’ safety.

“The levels of these ingredients they found are extremely small and are excreted from the body,” said Dr. Paul DeLeo, ACI Associate VP of Environmental Safety. “There’s a wide margin of safety between these levels and the levels deemed unsafe based on standard safety evaluation. The weight of evidence supports the conclusion that these ingredients are not causing adverse effects on the endocrine system. The continued ‘suggestions’ that the presence of these substances are leading to health risks are not borne out by the data and years of safe use by consumers.”

In comments submitted last year to the FDA on the safety of triclosan, ACI stated “Triclosan-containing consumer antiseptic wash products play a beneficial role in the daily hygiene routines of millions of people throughout the U.S. and worldwide. They have been and are used safely and effectively in homes, hospitals, schools and workplaces every single day. Furthermore, triclosan and products containing it are regulated by a number of governmental bodies around the world and have a long track record of human and environmental safety which is supported by a multitude of science-based, transparent risk analyses.”

In November, New Jersey Governor Chris Christie signed bill S1909, which will remove approximately two dozen antiquated and anachronistic statutes from the state’s books. The bill addresses laws that have been “superseded or invalidated, or which are anachronistic in nature — i.e. belonging to an earlier time and irrelevant in the current legal, political, and social climate.”

It made sense to repeal some of the laws, which included permitting stallions, bulls and rams to run at large; forbidding occupations to persons infected with venereal diseases; killing an unmuzzled dog running at large; and feeding county prisoners.
However, a few of them didn’t really make sense to me; why is it no longer a crime to delay or detain homing pigeons or steal personal property from shipwreck victims? Anachronistic, maybe, but I think still valid in this heavily populated, pet-loving state with its often treacherous shoreline.

Needless to say, the soon-to-be-trashed “outdated” law that really made us sit up and take notice was the one that made it illegal to “sell spray paint without posting a sign warning juveniles of the penalty for graffiti.” We here at SPRAY were scratching our heads as to why that law was considered obsolete. It seems a perfectly sound law, not archaic at all. We were stumped and Gov. Christie attached no comment to a press release announcing he signed the bill, according to Matthew Friedman of The Star-Ledger.

The recommendations to strike the laws were made by the New Jersey Law Revision Commission. We reached out to them for comment, but as we went to press, had no reply.
SPRAY also reached out to Heidi McAuliffe, Executive Director of the Graffiti Resource Council (GRC), who confirmed that the requirement to post signs in retail stores that inform aerosol coatings customers that graffiti vandalism is illegal is fairly common in many jurisdictions. It is included in the Model Anti-Graffiti Regulation that was adopted by the International Municipal Lawyer’s Association some years ago and consequently, it has been incorporated into innumerable city and municipal ordinances all over the country. It is also included in the state laws of California and Rhode Island.

The GRC includes a provision for signs in retail stores in its guidance on how to develop an anti-graffiti regulation. Its advice is based upon the IMLA Model Law as it is one element of a successful comprehensive anti-graffiti regulation, McAuliffe told us. This type of signage helps make customers aware of the law and reminds citizens of the negative impacts of graffiti vandalism.

So why was the law stricken from the book in New Jersey? We just don’t know, but are trying hard to find out. Stay tuned to SPRAY for an update to this perplexing development.

Representatives of The Consumer Aerosol Products Council (CAPCO) recently exhibited at the 2014 National Resource Recycling Conference in New Orleans, LA. It was the second time that CAPCO attended the event that brings together professionals throughout the recycling industry, including material recovery facility (MRF) operators, waste haulers, equipment suppliers and recycling coordinators for local municipalities.
Also in attendance were some of CAPCO’s key partners, the Steel Recycling Institute (SRI) and Keep America Beautiful. CAPCO was able to make connections with new organizations to further its goals of increasing awareness about the recyclability of aerosol products among consumers; getting more recycling programs to accept empty aerosol products; and communicating its acceptance more consistently on carts and bins, waste-hauler and municipality websites and via other educational outlets.

Mark Rivers, VP, Technical Services at Aeropres Corp., catches the football of leadership at the Consumer Specialty Products Association (CSPA) Annual Meeting in Ft. Lauderdale, FL in December. Bill Wood, President of Faultless Starch, bequeathed his responsibilities as Chairman of the Aerosol Division to Rivers with the symbolic pass.

Farouk Systems will launch The Miss Universe Style Illuminate Line by Chi nationwide at the 63rd Miss Universe Pageant, set to air on NBC on Jan. 25. The host site will be Florida International University in Doral, FL. For over a decade, Farouk Systems, together with its Chi Hair Care brand, has partnered with and sponsored the Miss Universe Pageant. Both Chi Hair Care and the Miss Universe Style Illuminate Line will be used by Chi’s styling team, which will attend to the styling needs of nearly 90 contestants from different countries around the world.
According to Farouk Shami, Farouk Systems Founder & Chairman, “The Miss Universe Organization is well-known for empowering women and encouraging them to have the confidence they need to succeed in today’s world. We are honored to share this same passion and vision.”

The Hong Kong Society of Cosmetic Chemists (HKSCC) Cosmetic Innovation Summit was held in November at the Hong Kong Convention & Exhibition Center. The Summit was co-hosted by Hong Kong Cosmetic Technical Resources Center and Beijing ICJDC Ltd. Co., and was largely supported by Cosmoprof Asia, IFSCC’s International Speaker Program and InvestHK.

]]>http://www.spraytm.com/around-the-industry.html/feed0Corrosion terminology that applies to spray packaginghttp://www.spraytm.com/corrosion-terminology-that-applies-to-spray-packaging.html
http://www.spraytm.com/corrosion-terminology-that-applies-to-spray-packaging.html#commentsFri, 02 Jan 2015 15:27:47 +0000http://www.spraytm.com/?p=7281Happy new year, everyone. Corrosion science and engineering, like all technical fields, has its own jargon. I thought we’d start out this year by defining those corrosion terms and a few statistical terms that are used with spray packages and spray package components.

Service life (SL)
Spray package service lifetimes are defined as the length of time before packages leak product or propellant, valves leak propellant or partially full packages no longer spray. In other words, service lifetime is the amount of time during which spray packages and aerosol valves function properly.

Corrosion rate
A corrosion rate is the rate at which metal corrosion penetrates through spray package metals and coating delamination, such as blisters, spreads laterally along the spray package surface. Corrosion rates are typically expressed as mils per year (1 mil = 0.001 inches) or millimeters per year.
Corrosion rates can be estimated from storage test data by measuring the corrosion depth or the blister diameter and dividing this depth or diameter by the spray package age when it was evacuated and opened.

Estimated service life
Spray package and valve service lives can be estimated when the corrosion rate is known or estimated. In reality, corrosion rates are always estimates of the actual rates. Rates can be estimated from storage test container examinations and electrochemical measurements—when the proper instrument parameters, measurement parameters and models are used for the estimation. Estimated service lifetimes are statistical distributions of numerous individual lifetimes.

Estimated cumulative percent failure
The number of failures in a given container population at a given time is expressed as the cumulative percent failure level. Each percent failure has an associated estimated life. For example, if 12 containers perforated after one year of storage testing with 96 containers, the cumulative percent failure level after one year is 12.5%.
Please note that the percentage for a storage test with a limited number of containers (96 in this example) significantly overestimates the actual percent failure at one year for a production of several million containers. In other words, in this example, the 12.5% estimated failure level from the storage test is significantly higher than the actual rate for commercial containers.
Each failure time will have a different associated percent failure level and the percentage of failures increases with time. A theoretical failure level versus time graph would have an S-shape with 0% when containers are filled (day one) and 100% at some later time.

Commercial life
Commercial life is the period from when sprays are filled to the time when they are exhausted and put in the recycling stream. Commercial lifetimes are also a statistical distribution of times.
The lowest service life of a spray package and its associated percent cumulative failure should exceed the target commercial life and be less than the acceptable associated cumulative failure, respectively. The lowest acceptable service life and its associated acceptable percent failure are both determined by each individual company and the length of the commercial life for each family of products.

General corrosion
General corrosion is the penetration of metal corrosion over a large area of the spray package surface. General corrosion is also the delamination of a polymer or laminate film over a large area of the spray package surface.

Localized corrosion
Localized corrosion is metal corrosion or polymer/laminate corrosion in small areas of the spray package. There are three types of localized corrosion: pitting corrosion, crevicing corrosion and blistering.

Pitting
Pitting corrosion penetrates spray package metals through a very small area. Thus, pitting corrosion is often referred to as pin-hole corrosion. Pitting corrosion causes spray packages to leak product or propellant.

Crevice corrosion
Crevicing also attacks spray package metals and occurs in the areas where two pieces of spray package material are joined together through seaming or welding. Both seaming and welding create a narrow crevice between the two separate pieces that allows formation of corrosive microenvironments inside the crevice.
Crevices are found in the a) top and bottom double seams for tinplated steel and tin-free-steel aerosol containers, b) the crimp area between the aerosol valve and aerosol container, c) the weld area between internal laminated-foil bags and the aerosol valve, and d) the various body welds for internal laminated-foil bags. Welds in tinplated steel and tin-free-steel aerosol containers are typically too shallow to be crevices.
Crevice corrosion could be general corrosion inside the crevice area, pitting corrosion inside the crevice area or both general and pitting corrosion.

Blistering
Blistering is a localized form of polymer coating and laminated film corrosion. Blisters grow laterally along the surface of the spray package. Blisters reduce spray package service life when pieces of coating or laminate film break free from the package surface and plug the holes in valve orifice(s).

Accelerated testing
Market time constraints often make it desirable to accelerate spray package corrosion testing. There are two traditional methods for accelerating corrosion: exposing packages to higher storage test temperatures and electrochemical corrosion testing.

Higher storage test temperatures
Raising test temperatures typically does not accelerate metal and polymer corrosion because the Arrhenius law does not apply to the corrosion process. It’s been observed by myself and numerous others that higher storage test temperatures stop the natural corrosion process that occurs at room temperature and often produce corrosion that is not naturally observed at room temperature—hence corrosion appears to be more intense, leading to the conclusion that a higher test temperature is accelerating corrosion.
Higher temperatures are only accelerating a process when there is an approximately doubling of the corrosion rate with each 20° increase in temperature and the process is controlled by the chemical activation energy of the process (corrosion is an electrochemical process and not a chemical process). There are numerous instances in corrosion literature where it was concluded that corrosion is not accelerated by increasing temperature.

Electrochemical corrosion testing
Electrochemical corrosion testing does not actually accelerate the natural spray package corrosion. The instruments used for electrochemical corrosion testing are very sensitive and thus detect and measure corrosion when it begins and measure corrosion long before it can be seen with the unaided eye or a light microscope. Thus, electrochemical corrosion tests actually provide accelerated results instead of accelerating corrosion. Attempts to accelerate spray package corrosion with applied electrical voltages have always failed.
We would be happy to teach our Elements of Spray Package (Aerosol Container) Corrosion short course at your R&D facility. Contact rustdr@pairodocspro.com or visit
www.pairodocspro.com. Want a specific topic discussed in an issue of Corrosion Corner? Please send your suggestions/questions/comments. Back articles of Corrosion Corner are available from Spray. Thanks for your interest and I’ll see you in February.

The Consumer Product Survey is ongoing. CARB held a webinar on December 15 to assist consumer product companies in filling out their surveys. This is a time consuming activity. Remember, the better information we put into the system, the better our regulation development should be. The survey needs to be completed by March 1, 2015.

LVP

As stated last month, the LVP studies are ongoing. The industry needs to closely monitor these studies to ensure that the protocols being used to test the LVP compounds are within the realm of reality. For example, the LVP compounds need to be tested using real world conditions—not just tested to determine if the LVP compound can volatilize to create ozone, but to tested under normal conditions to determine if the LVP compounds do indeed volatilize. This is a subtle but very important difference. It means more hands-on work for our scientists. However, we do not have a choice. Industry needs to maintain the LVP exemption as is or we need to go back to CARB and alter the VOC limits. Remember, the majority of VOC limits are based on the use of LVP compounds. Thus, it is time to get involved with this issue!

VOC limits

Remember, some aerosol coating categories became effective on 1/1/2015. These were the Specialty Coating categories. All the amendments from September 2013 are now effective, which means HFO-1234ze is now an exempt propellant. The definitions for single use cleaners and degreasers are effective. Take care in labeling these types of products. Remember, these products are single use and should not have multiple claims. Enforcement is watching closely.

Product Dating/Date coding

Date code information needs to be reported to CARB every year by your company if you do not use CARB’s standard date coding. California Section 94512 (b) product dating specifically requires that all consumer products to be sold into the state display the day, month and year that the products was manufactured—or a code indicating the date. CARB has been increasingly active investigating and levying fines for non-compliance.

The date or date-code information must be located on the container or inside the cover/cap so that it is readily observable or obtainable (by simply removing the cap/cover) without irreversibly disassembling any part of the container or packaging. Information may be displayed on the bottom of a container as long as it is clearly legible without removing any product packaging.

CARB’s standard code, which has to be represented separately from the other codes on the product container so that it is easily recognizable, is the following: YY DDD (Year Year Day Day Day). A manufacturer who uses this standard CARB code to indicate the date of manufacture does not have to report their code.

Failure to register a date code is subject to a fine. Every year the fines seem to go up. Your date code explanation needs to be submitted to the enforcement on an annual basis, on or before January 31st of each year. Date coding information is to be sent directly to Steve Giorgi at sgiorgi@arb.ca.gov.

Green Chemistry

The Department of Toxic Substance Control (DTSC) is still working on the original three priority products. In addition, DTSC is working on their three-year plan.

SNAP

Proposed Rule amendments had comments submitted by Industry on October 21. Not directly linked to this issue, but still important, is the ruling by the International Trading Commission (ITC) stating that Chinese imports of HFC-134a did not harm U.S. Industry. This means that HFC-134a will remain less expensive, and may motivate the EPA to keep the deadline for prohibition where it is at or at least not move it out as far.

OTC

Remember, the New Hampshire Department of the Environment proposed changes to their consumer product regulation. We expect the changes to pass. A full table of the new VOC limits can be accessed at www.spraytm.com under the “Regulatory Issues” section.

The study estimates that global aerosol demand reached 14.61 billion units in 2013, and expects that figure to rise at a CAGR of 3.1% through 2020, at which point it will reach 18 billion units.

Aerosol applications for household products are expected to see the fastest per capita growth of any segment, with a CAGR of 3.5% through 2020. Regionally, Grand View predicts “Asia Pacific” to grow at a CAGR of 4.1% during the time period due to relaxed regulations and increasing demand for aerosols in the cosmetics industry.

The report lists large global manufacturers, such as Procter & Gamble, SC Johnson, Henkel and Reckitt Benckiser, as key participants who will drive innovation that focuses on reducing raw materials usage and increasing recyclability.

]]>http://www.spraytm.com/global-aerosol-market-to-reach-70b-by-2020-study-says.html/feed0Schoolscience promotes aerosols as educational toolhttp://www.spraytm.com/schoolscience-promotes-aerosols-as-eduactional-tool.html
http://www.spraytm.com/schoolscience-promotes-aerosols-as-eduactional-tool.html#commentsFri, 05 Dec 2014 21:20:11 +0000http://www.spraytm.com/?p=7229Schoolscience, the website for school students and science teachers in the UK, has recently featured on the Association for Science Education website an article promoting its new interactive resource on the physics and engineering that go into making aerosols.

Nick Swift, author of the article and Editor for Schoolscience, wrote: “It turns out that aerosols make an excellent case study for the gas laws, heating effect of electric current, pressure units, vapour pressure, absolute temperature, volatility, ideal gases and the hard-to-grasp ideas of liquids that boil well below zero degrees Celsius”.

The resource was created by Nick Swift with what he describes as ‘invaluable assistance from the British Aerosol Manufacturers’ Association (BAMA). He said: “BAMA gave me access to this fast-moving industry to learn first-hand how aerosols are developed and manufactured. It is a high speed precision engineering business that requires massive capital investment. It is important that young people appreciate how they work, that they can be recycled and that they show physics and chemistry in action.”

Amy Falvey, Communications Manager for BAMA, said: “The aerosol sector in the UK is a significant and successful industry. We are keen both to share the resources we have in helping school students better understand the science behind aerosol technology but also to encourage potential scientists to consider our industry as a possible career path”.

President Obama quietly signed the bipartisan Sunscreen Innovation Act into law on Nov. 29. The legislation is meant to clear the backlog of sunscreen ingredients pending FDA action—some for over a decade.

Skin cancer is the most common cancer diagnosed in the U.S., which is why members of Congress and the House Appropriations Committee have chastised the FDA for taking so long on sunscreen ingredients, especially ingredients already widely used in Europe and Asia.

The last approval for widespread use of a sunscreen ingredient was in 1990. But since 2002, there have been eight ingredients submitted to the FDA that are still awaiting the agency’s review. Many of these ingredients haven’t received any FDA attention for years, not even negative feedback. The new law will force the FDA to make timely decisions on each of the pending ingredients within a specific timeframe. Some decisions are expected to be made within six months. New ingredients added since the law is enacted must be responded to within a year.

Source: Time

]]>http://www.spraytm.com/president-obama-signs-the-sunscreen-innovation-act-into-law.html/feed0What happens when spray packages corrode?http://www.spraytm.com/what-happens-when-spray-packages-corrode.html
http://www.spraytm.com/what-happens-when-spray-packages-corrode.html#commentsTue, 02 Dec 2014 20:59:23 +0000http://www.spraytm.com/?p=7168
Hello everyone. Is corrosion-free spray packaging a realistic expectation? What can happen when a spray package corrodes? This month we’ll examine the various scenarios that could occur when a formula causes spray package corrosion, and the options for living with corrosion.

Corrosion Basics: Spray package lifetime

All spray products have a lifetime during which the product and the package both perform as specified. This lifetime is often referred to as shelf life.

However, the term shelf life usually applies to products with active ingredients, such as pharmaceutical products and insect control products. For example, a five-year shelf life indicates that the effective medical ingredient concentration in the package is around 50% after five years.

I prefer the termservice lifetime when discussing spray packages. Service lifetime is the length of time when packages perform as specified—that is, packages spray until the product is exhausted and do not leak product.

General corrosion occurs over the entire internal package surface or in large patches on the surface. Localized corrosion occurs at small points—pits and coating/laminate blisters of 50 microns or less in diameter—or in areas where two pieces of material overlap (such as aerosol container double seams and laminated bag welds). Corrosion in overlapping areas and bag welds is referred to as crevicing.

There are two ways to address corrosion issues. Corrosion could be preventedor controlled by reformulating with or without a corrosion inhibitor.

Corrosion prevention means that corrosion is not present during the specified service life of the spray package. Corrosion prevention is typically achieved with a corrosion inhibitor or by changing to a different type of spray package.

Corrosion inhibitors have effective concentration ranges like all of a formula’s ingredients. Too much or too little of a corrosion inhibitor could actually cause or exacerbate corrosion. Consequently, quality specifications should include analysis for the corrosion inhibitor concentration in each manufacturing batch prior to spray package filling.

Corrosion is present withcontrol. However, very slow corrosion usually does not reduce service life below the specified target or appear to degrade product efficacy. In other words, package service life is extended through control and control is also probably reducing the corrosion-degradation of product efficacy.

The quality specifications should also include analysis for corrosion inhibitor concentration prior to spray package filling when a corrosion inhibitor is used to control corrosion. In addition, commercial spray packages should be periodically retrieved and inspected for corrosion when using corrosion control. Determination of corrosion inhibitor concentration and measurements of product efficacy is also recommended during these inspections. Inspections should be conducted throughout the commercial life of the product.

Periodic inspections of commercial packages help to ensure that variability does not cause the inhibitor to lose its effectiveness and the service life to decrease below the target length.

A comprehensive corrosion control and prevention program includes corrosion testing prior to commercialization of the product. There are two general categories of corrosion tests for spray packaging: storage stability tests and electrochemical corrosion tests.

Storage test data can be used to estimate service lifetimes, and thus provide information for decisions on the suitability of a product-package system for a commercial market. Electrochemical corrosion test data can also be used to estimate service lifetimes with the appropriate empirical models.

Good practices for stability tests should:

include periodic destructive inspections of test samples for internal package and valve corrosion (for example, inspections every three or four months)

have replicate package samples examined at each inspection interval (more than three packages)

use high temperature test conditions for product thermal stability determination and not to accelerate corrosion

be conducted for at least one year before commercialization decisions are made

Electrochemical tests are shorter than storage tests because the instruments used for detecting corrosion are more sensitive than the human eye and a light microscope. The correlation between electrochemical results and actual corrosion are very high when the appropriate test parameters are used for the measurements (in excess of 99%).

Sometimes products are abandoned during development because corrosion was found in storage stability tests. However, it has been my experience that corrosion does not always indicate that a product should be abandoned. Indeed, I prefer to think that the development timetable needs to be extended when corrosion is found.

My preference is for prevention. However, individual companies must decide whether corrosion control or corrosion prevention is appropriate for a given commercial spray product.

We would be happy to teach our Elements of Spray Package (Aerosol Container) Corrosion short course at your R&D facility. Contact rustdr@pairodocspro.com or visit www.pairodocspro.com. Please send your questions/comments/suggestions to rustdr@pairodocspro.com. Back articles of Corrosion Corner are available from Spray. Thanks for your interest and I’ll see you in January.

The California Air Resources Board (CARB) continues with its 2013 Consumer Product Survey. If you sold a Consumer Product into the state of California in 2013 and your product is on the CARB survey form, then you are responsible to fill out the survey (it is state law as well). The CARB survey is very comprehensive and covers most products. It is important that this survey is filled out correctly as it is used to develop future consumer product volatile organic compound (VOC) regulations. Therefore, the better the information, the smoother the rule development process goes.

LVP Studies

On Oct. 31, 2014, CARB conducted a meeting to review the low vapor pressure (LVP) studies being conducted by The University of California (UC) Davis and UC Riverside. The preliminary data and ongoing work were discussed among the workgroup. Numerous compounds are being studied to determine their fate in the atmosphere and if they contribute significantly to the formation of ozone. If the compounds are found to contribute significantly to ozone formation, then CARB may need to consider amending the definition of LVPs and ultimately their use. We will need to wait and see what the results show.

SCAQMD

South Coast Air Quality Management District (SCAQMD) hosted a Symposium on Assessing & Managing Toxic Risk from Alternative VOC compounds on Oct. 29. The meeting was held to discuss how to handle compounds that have been exempted by the U.S. Environmental Protection Agency (EPA) but not by SCAQMD. Examples of these compounds are Tertiary Butyl Acetate (TBAC) and Dimethyl Carbonate (DMC). SCAQMD has allowed some use of these compounds but not fully declared them VOC exempt. If these compounds were fully exempt, then manufacturers could use them as substitutes for VOCs, thus lowering the VOC content of the products.

There was significant push back from the environmental community to exempt these compounds as VOCs. It will be interesting to see what action SCAQMD takes as a result of this Symposium.

OTC

On Oct. 21, The New Hampshire Dept. of Environmental Services (DES) changed its VOC regulation that was to take effect Jan. 1, 2015. The change was to extend the effective date for all categories that were based on the current Ozone Transport Commission (OTC) model. The new effective date is Jan. 1, 2017. This is confusing, since New Hampshire has a regulation with current limits, will have limits that become effective in January of 2015 and other limits that will be effective January 1, 2017.

Shortly after I drafted last month’s article, Limited Quantities—Size Matters, I received a phone call from a very large cosmetic manufacturer in Los Angeles, CA. Even though this company ships hundreds of millions of dollars in freight annually, they were having issues with their carriers with respect to the placarding of freight containers that were being drayed to the port for carriage aboard cargo ships bound for various international destinations.

After a lengthy interview with the International Logistics Coordinator, it appears that the carrier was charging the manufacturer exorbitant freight surcharges because of the carrier’s misconception that the container was required to be “placarded” with the hollow diamond with black points.

Limited Quantities

As I stated in last month’s article, a “…limited quantity of a hazardous material means the maximum amount of a hazardous material for which there is a specific labeling or packaging exception. Whether or not a hazardous material may be shipped as a limited quantity is dependent upon the following factors: (a) the hazard class and division for the substance or article; (b) the size of the inner receptacle; and (c) the total gross mass of the completed package…

“There are also certain economic advantages to shipping a hazardous material as a limited quantity, including reduced hazard communication requirements for surface and ocean transport, and an exception from the shipping paper requirements for surface transport. Additionally, many carriers have reduced shipping rates or surcharges for limited quantities compared to fully-regulated dangerous goods shipments.”

Obviously, in this case, the carrier, as well-intentioned as it might be, is apparently charging the manufacturer costly hazardous materials surcharges because they dispatch only drivers that have a Hazardous Materials Endorsement to the Commercial Drivers’ License (CDL).

Nomenclature

Hazard warning label

Although the enlarged Limited Quantity Marking applied to the four sides of an intermodal freight container have dimensions identical to the hazard-warning placards applied for international ocean shipments (250 mm x 250 mm), the Limited Quantity Marking is not a “placard” as most people erroneously assume.

The U.S. Dept. of Transportation (DOT) has a number of “reserved” terms including “labels,” “placards,” “markings,” “marks” and “panels,” all of which help to communicate the risks associated with dangerous goods.

Cargo handling label

The term “labels” refers to the hazard warning signs applied to packages of hazardous materials such as drums, boxes, bags and cylinders. “Labels” can also mean “cargo handling labels,” such as the orientation arrows that indicate that liquids are contained within a combination packaging and should be stored and handled in an upright position. Labels are typically 100mm x100 mm and applied to a package in a diamond (or square-on-point) configuration. Interestingly enough, there is no regulatory requirement in the U.S. that the hazard warning labels be applied to a package in a diamond configuration; this is another common misconception. However, there is such a regulatory requirement in Canada.

Placard

“Placards” are “enlarged labels” applied to cargo transport units e.g., freight containers, cargo tanks, rail cars, trailers and bulk packaging (such as ISO tank containers, Intermediate Bulk Containers, “totes” and “supersacks”). Unlike labels, placards must be applied to the exterior surfaces of the cargo transport unit or bulk packaging in a diamond (or square-on-point) configuration and in such a manner to promote visibility, e.g., at least five feet in from the corner post and five feet up from the bottom rail of an intermodal freight container.

A “mark” or “marking” is neither a label nor a placard but rather another form used to communicate special warnings or information associated with the products being carried. The term “mark” or “marking” may refer to a UN specification packaging marking or DOT mark applied to drums (e.g., 1A1), cylinders (e.g., DOT-39 NRC), boxes (e.g., 4GY) or even aerosol cans (e.g., 2P, 2Q, 2S). A “marking” can also refer to a fumigation warning applied to freight containers that are being carried while actively under fumigation, or a marine pollutant mark applied to indicate that cargo is particularly hazardous to the aquatic environment.

Marine Pollutant Marking

“Panels” are orange rectangles with a thick black border into which you apply the 4 digits of the UN or NA identification number, and which are applied to bulk packaging or cargo transport units carrying bulk quantities or certain threshold amounts of dangerous goods.

A Limited Quantity marking is a symbol, applied to packages in a square or diamond (preferred by DOT, however required internationally) configuration. It is used to indicate that the products within the combination packaging are dangerous goods that are packaged in a form that is suitable or intended for retail distribution and that have a lesser risk than fully regulated products and quantities of the same substance.

Panel signifying UN 1993

The “enlarged” limited quantity marking may be applied to cargo transport units—such as trailers or freight containers—by surface, but are required when freight containers are interchanged at the marine terminal for lifting onto the cargo ship. The “enlarged” limited quantity marking is applied to each of the four visible sides of the freight container in the same manner as placards; however, the Limited Quantity Marking on a freight container means that all of the dangerous goods within the container (regardless of cubic volume) are in limited quantities. It is important to note that it doesn’t matter how many pallets of limited quantities may be shipped in a freight container—it may be one pallet or 20, up to the maximum allowable payload for the freight container. If any amount of the cargo within the freight container requires hazard warning labels, then the “enlarged” limited quantity markings would not apply to the freight container, but rather the freight container must be placarded on the four visible sides for the cargo requiring the hazard warning labels. In a sense, you would never have a situation where the hazard warning placard and limited quantity marking would appear on a freight container at the same time.

Limited quantity marking

For example, a typical 20″ closed freight container can carry up to 30 cubic meters (or 20 pallets that are five deep, two wide, two high). Let’s assume, in this case that three pallets contain 100 boxes, each containing twelve 16.9oz (500 mL) flammable aerosols. The remaining 17 pallets do not contain hazardous materials of any type. The Limited Quantity Marking would be applied to each of the four visible sides of the freight container.

However, if I have three pallets of the flammable aerosols previously described, have 16 pallets of non-dangerous goods, and add one pallet containing 27 five-gallon pails of a solvent-based (flammable liquid) paint, the freight container no longer contains dangerous goods that are only in limited quantities. Therefore, it must be placarded on all four sides with the Flammable Placard and the Limited Quantity Marking would not apply.

Hazardous Materials Endorsements

The U.S. Federal Motor Carrier Safety Administration (FMCSA) is the regulatory agency that develops and enforces the requirements for licensing and qualification of drivers, maintenance and inspection of vehicles, carrier safety and fitness, drug and alcohol testing, and drivers’ hours of service. FMCSA is not the regulatory agency that develops the DOT’s Hazardous Materials Regulations (HMR). The HMR is developed by the U.S. Pipeline & Hazardous Materials Safety Administration (PHMSA, pronounced fim-zuh). The DOT’s modal agencies (e.g., Federal Aviation Administration, Federal Railroad Administration, Federal Highway Administration, FMCSA) are the DOT’s enforcement arms for their respective modes of transportation. PHMSA generally enforces the requirements for packaging marking, manufacturing and design, even though each modal agency can equally enforce these requirements.

CFR defines a “hazardous material” as “any material that has been designated as hazardous under 49 U.S.C. 5103 and is required to be placarded under subpart F of 49 CFR part 172 or any quantity of a material listed as a select agent or toxin in 42 CFR part 73.”

A quick search of the placarding requirements in 49 CFR Part 172, subpart F, §172.500 reveals that the “placarding” requirements do not apply to limited quantities and Consumer Commodities. See below:

§172.500 Applicability of placarding requirements

Each person who offers for transportation or transports any hazardous material subject to this subchapter shall comply with the applicable placarding requirements of this subpart.

This subpart does not apply to —

Infectious substances;

Hazardous materials classed as ORM-D;

Hazardous materials authorized by this subchapter to be offered for transportation as a limited quantity when identified as such on a shipping paper in accordance with §172.203(b) or when marked as such in accordance with §172.315.

Hazardous materials prepared in accordance with §173.13 of this subchapter;

Hazardous materials which are packaged as small quantities under the provisions of §§173.4, 173.4a, 173.4b of this subchapter; and

Combustible liquids in non-bulk packaging.

]]>http://www.spraytm.com/limited-quantities-costly-misconceptions.html/feed0Canada gets closer to GHS implementationhttp://www.spraytm.com/canada-gets-closer-to-ghs-implementation.html
http://www.spraytm.com/canada-gets-closer-to-ghs-implementation.html#commentsMon, 01 Dec 2014 21:05:02 +0000http://www.spraytm.com/?p=7170Since my article in the September issue of SPRAY, Canada is one step closer to adopting the Globally Harmonized System (GHS) by updating the Workplace Hazardous Materials Information System (WHMIS). However, there are still several steps to go until Canada catches up with the U.S. and has a GHS-based law.

On Aug. 8, Health Canada reviewed the public feedback to the 2013 draft regulation and used it to issue an updated draft. There was a comment period, which ended on Sept. 8, 2014. We are not expecting any significant changes to this most recent draft when the final rule is released. The new draft regulation is available for download at:

The new rule will update the rules governing Material Safety Data Sheets (now simply called Safety Data Sheets [SDS]) and workplace chemical labels, but not the Consumer Chemicals & Containers Regulations, 2001 (CCCR, 2001) governing consumer chemicals in Canada. To avoid confusion, I will refer to old WHMIS as the existing rules and new WHMIS to be the rules based on GHS. The expected roll-out of new WHMIS is expected to look as follows:

Phase 1 – Transition (July 2015 to June 2016)

During this period, manufacturers and importers will convert their SDS and labels to the new WHMIS format. Importers and manufacturers can use SDS and labels in either old WHMIS or new WHMIS formats.

Importers and manufacturers must supply SDS and labels in only new WHMIS format. Distributors, however, can ship products in either format to allow for a sell-through of old stock and workplaces can use product labels and SDS in either format.

Phase 3 – Distributor Compliance (January 2017 to June 2017)

Distributors must now follow only new WHMIS, as well. Canadian workplaces will have until June 2017 to ensure that the labels and SDS of the products they use are new WHMIS compliant.

Note that these timelines are not set in stone, but rather our best estimates based on what we have heard from a number of industry groups and trade associations.

There have been some concerns that the release of the final rule may be delayed due to the tragic events in Ottawa in October. In my view, this is unlikely. It is remarkable how quickly Parliament Hill went back to business, so it is not likely to cause any delays.

There is a significant amount of changed text in the 2014 draft rule relative to the 2013 draft rule, but the overall effects are minor. The largest change, in Nexreg’s view, is that under the 2014 draft rule, there are new requirements for “substances and mixtures that, upon contact with water, release a gaseous substance that is acutely toxic.” That is fairly small stuff, and not something that should impact too many companies.

More important are the items that were not changed between the 2013 and 2014 drafts, including the following:

Disharmony with the U.S.: There are still significant differences between this draft and the U.S. Hazcom 2012 rules, including the classification criteria for pyrophoric gases, simple asphyxiants and combustible dusts. Rules around the disclosure of carcinogenic ingredients also differ between the two countries. Because of these (and many more) differences, companies will not be able to simply use their U.S. labels and SDS in Canada due to differences in regulations. However, in almost all cases, it will be possible to create a set of documents that are jointly compliant with Canada and the U.S.

Label Design: The hatched WHMIS border will no longer be a requirement on workplace labels, nor will the statement about the availability of a Material Safety Data Sheet.

Flavors & Fragrances: The current Canadian exemption that allows for non-disclosure of flavors and fragrances will not be retained.

Renewal of Labels and SDS: The current requirement to update a Material Safety Data Sheet every three years will not be retained. However, companies must ensure that their SDS and labels remain accurate and must update these if new information becomes available about the composition of the mixture or the substances comprising it.

Exact Concentrations: Under the 2014 proposed rule, companies will not be able to use “WHMIS ranges” for the concentrations of components in their mixture. Rather, exact percentages must be used, unless there is a known variance in the raw material or manufacturing process.

Trade Secrets: In Canada, companies cannot self-declare that chemicals in a mixture—or their concentrations—are a trade-secret. Rather, they must apply to the Federal government to make such claims. Given the requirement for exact concentrations on SDS, we expect many companies will want to make trade secret claims. In order to do so, a company must register the chemical in question with Health Canada and obtain a HazardousMaterials Information Review Act (HMIRA) number.

Small Volume Containers: The 2014 draft rules have special provisions for reduced labeling requirements on containers of 100mL or smaller. These do not exist under the U.S. Hazcom 2012 regulation.

Products with Multiple Containers: Kits and other products with multiple containers (two-part epoxies are a classic example) require both the inner containers and the outer container (such as a box) and must have workplace labeling under the 2014 draft rules. This is not the case under Hazcom 2012.

We will keep watching the progress of GHS around the world. Do not be surprised to see jurisdictions that have already implemented the system update their laws to be closer to GHS Revision Five, including the U.S. When that happens, we will be sure to inform SPRAY readers.

More than 250 exhibitors, international leaders material suppliers meet visitors on the subject of material expertise to talk about the state of the art: material; converters and injectors; case manufacturers; suppliers of assembly technologies; TTS and decoration; BOV, valves, pumps, dispensing technologies and applicators; products and technologies; private labels.

To boost innovations and technology transfers, ADF will take place at the same time as PCD (Packaging of Perfume Cosmetics & Design), 1st field of use of aerosols and dispensing technologies.

During the 2 days of conferences, 10 sessions, 90 speakers representing the highest level of international expertise with sustainability as a common theme will enhance the visit of the exhibition.

9th ADF Edition will take place February4 & 5 at the Espace Champerret, Paris.

SCHEDULE:

Wednesday – February 4th 2015

Opening of the exhibition

09:15-11:00 Me1 – C02 and N2O, compressed gases for what purposes? What are the technical constraints?

Designed to inspire holiday shoppers to give “the gift of feelings,” Glade opened up its first-ever Boutique in New York City. From now until Dec. 23, shoppers traversing the cobblestone streets of Manhattan’s trendy Meatpacking District can stop in for a free journey through five dazzling, interactive spaces, each inspired by and infused with one of Glade’s fragrances.

Inspired by Sparkling Spruce

The idea behind the Glade Boutique is to show how scent can alter the way people feel–and even inspire them to lend those feelings to others.

Upon entering, visitors are invited to relax in the “Feelings Lounge,” decorated by famed designer Stephanie Goto, based on the feelings she drew from Glade’s fragrances. In the first room, visitors find themselves in a wintry forest, where snow-covered boughs emit Glade’s Sparkling Spruce fragrance.

Flirty, inspired by Blooming Peony & Cherry

Next, the Relaxation Room, inspired by Hawaiian Breeze, is the inside of a larger-than-life conch shell through which a relaxing warm breeze flows. The third room, Flirty, invites guests for a personal fashion photo shoot and the opportunity to step into a luxury gown created by designer Pamela Dennis, all while Blooming Peony & Cherry fills the air. After the Clean Linen room, visitors take part in an exhilarating 3D virtual reality ride, the Energized room, over a blooming meadow and down a waterfall while experiencing Glade’s Red Honeysuckle Nectar fragrance.

Before leaving, guests are invited to visit Glade’s Scent Lab, offering an up close experience with Glade’s fragrance catalog, including some scents due to hit the market in 2015.

The Energized experience

The Glade Boutique is located at 408 W 14th St. in New York, NY and is open from Nov. 18 to Dec. 23, 11am-8pm Mon-Fri, 10am-8pm Sat and 11am-7pm Sun. It will not be open on Nov. 27, Thanksgiving Day.

]]>http://www.spraytm.com/feel-glade-boutique-debuts-in-manhattan.html/feed0Sunscreen Innovation Act awaits President’s signaturehttp://www.spraytm.com/sunscreen-innovation-act-awaits-presidents-signature.html
http://www.spraytm.com/sunscreen-innovation-act-awaits-presidents-signature.html#commentsTue, 18 Nov 2014 14:31:19 +0000http://www.spraytm.com/?p=7100With passage of the Sunscreen Innovation Act (S. 2141) by the U.S. House of Representatives, the bill is set to go to President Obama for his signature and enactment into law. This important bill reforms the current sunscreen approval process of the U.S. Food & Drug Administration (FDA) by creating a timely and transparent process by which FDA will evaluate applications for new, safe and effective sunscreen ingredients, which are regulated as over-the-counter (OTC) drugs.

“As a member of the Public Access to Sun Screens (PASS) Coalition, BASF highly welcomes the Sunscreen Innovation Act. Passage of the bill represents a significant step towards ensuring the timely review of new sun protection ingredients by the FDA, that will ultimately provide U.S. consumers with a wider array of safe and effective sunscreen products,” said Dirk Buengel, Senior VP, Care Chemicals for BASF in North America.

If signed into law by President Obama, the Sunscreen Innovation Act will help provide Americans access to the latest sunscreen ingredients, some of which have been widely available for 15 years in Europe, Asia and Latin America.

Romesberg, the plant’s manager from March 2009 until getting promoted in July 2013, said she finds it “exciting for the plant to add a new production line.”

That’s because it not only means more local jobs — the company has pledged to create at least 21 over three years — and a $9 million capital investment, but also because it could lead to further expansion of the plant if the new production line delivers the cost-savings the company is seeking, Romesberg said.

The new manufacturing facilities will give the plant the capability to produce aerosol products, starting with spray-on versions of Energizer’s Hawaiian Tropic and Banana Boat suncare products, she said.

The plant also produces liquid versions of Energizer’s Edge and Skintimates shaving creams, but not the gel versions that come in cans, at least not yet, she said.

Energizer decided to install the new manufacturing facilities here after also considering its plants in other parts of the country.

What tipped the scales in favor of Ormond Beach, Romesberg said, were the economic incentives recently approved by the city and state, much of it contingent on the company making good on its pledge to create jobs that will pay an average annual wage of $39,000.

The plant employs 199 full-time workers year-round, but adds seasonal workers, at times more than 100 a day, during peak production season for suncare products, which Romesberg said runs from October through March.

Romesberg said the company has been outsourcing production of its Hawaiian Tropic and Banana Boat aerosol suncare products to contract manufacturers.

CLOSE CALL

Energizer’s decision is a victory for the city, which came close to losing the plant after the home-grown Hawaiian Tropic company was sold in May 2007 to Playtex Corp., maker of the then-rival Banana Boat suncare line. Playtex had been outsourcing production of Banana Boat and was expected to do likewise with Hawaiian Tropic.

“I asked them to compare the cost benefits of outsourcing versus manufacturing in Ormond Beach,” recalled Mannarino, who after several months finally got a response from the Playtex official who had listened to his pitch. The official had both “good news and bad news,” Mannarino said.

The good: Playtex officials agreed it made more sense to keep the Ormond Beach plant. The bad: Playtex was being acquired by Energizer, which meant the evaluation process would need to start over again.

Energizer kept the plant.

“We have a great relationship, not only with Joe but also the rest of the city,” Romesberg said, adding: “If I’m successful, I want to keep growing the plant.”

Source: The Daytona Beach News-Journal

]]>http://www.spraytm.com/energizer-exec-plans-to-expand-florida-aerosol-facility.html/feed0Recycle aerosols on “America Recycles Day” and every dayhttp://www.spraytm.com/recycle-aerosols-on-america-recycles-day-and-every-day.html
http://www.spraytm.com/recycle-aerosols-on-america-recycles-day-and-every-day.html#commentsMon, 17 Nov 2014 15:56:01 +0000http://www.spraytm.com/?p=7093November 15 was America Recycles Day. More than 10 million aerosols are manufactured each day in the U.S. for products ranging from shaving cream to bicycle lubricant. The Consumer Aerosol Products Council (CAPCO) reports that nearly four billion aerosol cans are produced in the U.S. annually for products.

These empty aerosol products can be recycled and are increasingly being recycled. More U.S. municipalities are accepting empty aerosol containers making it easier for U.S. consumers to toss used shaving cream cans and bicycle lubricants, cooking sprays and spray sunscreens into their bins.

More can be done. The Consumer Aerosol Products Council (CAPCO) is pleased that, after 20 years of awareness efforts, more than 5,300 U.S. municipalities now include aerosol cans in their recycling programs. Many, however, remain unaware that these products are recyclable.

“We are pleased that more than 65 percent of Americans have access to aerosol recycling through curbside pickup, drop off and waste-to-energy recovery programs,” said D. Douglas Fratz, CSPA Aerosol Products Division Staff Executive and Senior Science Fellow, whose organization represents the aerosol industry. “But the remaining 35 percent must be addressed. We have only one goal in mind, 100 percent,” Fratz said.

Recycling empty aerosol containers is as easy as 1-2-3:
1. Empty the aerosol of its contents through normal use.
2. Check instructions from the local collector to determine if empty aerosols are accepted.
3. Place empty aerosol container in bin along with other recyclables.

The CAPCO is a CSPA affiliate organization, working with CSPA’s Aerosol Products Division members to provide factual information to consumers about aerosol products. For more information about aerosol product recycling visit www.AerosolProducts.org.

About CSPA

The Consumer Specialty Products Association (CSPA) is the premier trade association representing the interests of companies manufacturing, formulating, distributing and selling more than $100 billion annually in the U.S. of familiar consumer products that help household and institutional customers create cleaner and healthier lives.

]]>http://www.spraytm.com/recycle-aerosols-on-america-recycles-day-and-every-day.html/feed0Nov. 24 Webinar: Top 10 Packaging Challenges for Recycling in a MRFhttp://www.spraytm.com/7090.html
http://www.spraytm.com/7090.html#commentsFri, 14 Nov 2014 20:56:35 +0000http://www.spraytm.com/?p=7090This PAC NEXT webinar will share the key findings of the Top 10 Packaging Challenges in a MRF, a PAC NEXT project initiated to inform stakeholders, especially packaging producers, about end-of-life challenges for the recycling of packaging materials at a material recovery facility (MRF). The information presented in this webinar will aim to (1) inform stakeholders about why a package may or may not be recyclable and whether simple design changes can help increase recovery and recycling in a MRF, and (2) identify opportunities for improved communication and education across the value chain (including consumers) on how to make packaging materials more recyclable when sent through a MRF.

Join us for this one-hour PAC NEXT webinar with members of our project team – Daniel Lantz, Green By Nature, Keith Fanta, P&G, David Yousif, City of Hamilton, Trevor Barton, Region of Peel and Dick Lilly, Northwest Product Stewardship Council who will share their knowledge, experiences and insights.

The European regulation on chemical substances, Registration, Evaluation, Authorization and Restriction of Chemicals (REACH) called for the review of all chemicals based on the “precautionary principle” that requires additional data and possible action where safety is uncertain.

Presenters:

Join ICMAD International Committee Chair Carl Geffken and guest speaker, Marie Roussel, for an update on REACH and how it may impact beauty sales in the EU.

Beth Law is now Assistant General Counsel/Vice President of Stewardship & Sustainability. In this expanded role, Law will serve as the association’s lead on all retail-related issues, such as ingredient disclosure initiatives and product hazardous waste disposal. Law will also oversee CSPA’s efforts on product stewardship and sustainability.

Law, who has been with CSPA for 7 years, will also maintain responsibility as Division Staff Executive of the Pest Management Products Division and Staff Executive of the Environmental Marketing Claims Committee. Law holds a bachelor’s degree in history and political science from Case Western Reserve University and a juris doctor degree from Columbia University School of Law.

Tim Brown is now Regulatory Counsel and Director of International Affairs. Brown has been assisting CSPA and its member companies on international issues since joining the association in 2011. Brown will now take the lead on all international affairs issues for CSPA. In addition, Brown will continue in his roles as Division Staff Executive of the Cleaning Products Division and Staff Executive of the Regulatory Government Affairs Advisory Committee.

Brown holds a bachelor’s degree in science from Tulane University and a juris doctor degree from Loyola University New Orleans School of Law.

Sara Stickler is now the Executive Director of the Alliance for Consumer Education at CSPA, a 14-year old nonprofit founded to promote the responsible and beneficial use of products. Since joining CSPA, Stickler has been instrumental in expanding the reach of the ACE nonprofit and in promoting the Inhalant Prevention, Disease Prevention, and Poison Prevention programs.

Stickler joined ACE over two years ago following a 4-year career in education. Sara holds a bachelor of science in education from Xavier University and a master’s degree in public policy from the University of Maryland.

Labelmaster offers its Early 49 CFR book covering up-to-date domestic regulations for the shipping and transport of dangerous goods six months prior to release of the government 49 CFR. This exclusive resource includes requirements for markings, labels, placards, shipping papers, training, emergency response and packaging standards for hazmat transportation via highway, rail, air and water.

“This early version of the 49 CFR is imperative for all dangerous goods shippers, carriers and freight forwarders as well as those shipping hazardous materials or hazardous waste, because it provides the most current regulatory information to help keep companies up-to-date with new rules adopted between annual 49 CFR printings,” said Jeanne Zmich, Vice President of Regulatory Research with Labelmaster, a leading provider of solutions for hazardous material transport compliance. “The regulations are updated as of October 1st of each year, but the government’s release is not available until March.

“That’s why we developed the Early 49 CFR to get the regulations, with additional user-friendly features, out as soon as possible,” she added.

Labelmaster’s Early 49 CFR offers the same formatted information as Parts 100-185 of the government release, but also includes additional unique and user-friendly features, including:

A four-digit number cross-reference table

Easy-to-read Hazardous Materials Table

A detailed index to easily find regulations

Tabbed sections for easy reference

A “How to Use the CFR” section

Color displays of hazmat labels and placards

Adhesive tabs to identify sections

The Early 49 CFR is offered in a variety of formats including standard and spiral bound books, USB drive, and online edition as well as included in book combos. The 6″ x 9″ book is contained in a single volume which is easier to use than the government’s two volume set.

“The road to dangerous goods compliance is complicated and ever-changing and our Early 49 CFR publication helps companies – big and small – make sense of and comply with the regulations governing dangerous goods transportation,” said Zmich.

The Estée Lauder Cos., Inc. appointed Nancy Mahon to the position of Senior VP, Global Philanthropy & Corporate Citizenship. In this capacity, Mahon will be responsible for overseeing the company’s best practices and philanthropic and employee engagement programs. She will continue to serve as VP of Estee Lauder-owned MAC Cosmetics, where she heads the brand’s MAC AIDS Fund, a major worldwide funder of HIV/AIDS support and education. In 2011, President Barack Obama named Mahon Chair of the President’s Advisory Council on HIV/AIDS.

]]>http://www.spraytm.com/estee-lauder-names-nancy-mahon-vp-global-philanthropy.html/feed0New Line of Household Products Hits Walmarthttp://www.spraytm.com/new-line-of-household-products-hits-walmart.html
http://www.spraytm.com/new-line-of-household-products-hits-walmart.html#commentsFri, 07 Nov 2014 15:45:45 +0000http://www.spraytm.com/?p=7048
A new line of refillable household products has made its debut at Walmart. CleanPath personal care products from Replenish, including hand soap, hand sanitizer, multi-surface cleaner, bathroom cleaner and glass cleaner, are now available exclusively at the retailer.

With the ethos of reducing waste to a minimum, CleanPath products are sold in refillable plastic bottles. When the contents run out, consumers can purchase replacement concentrate pods that are mixed inside the container, with no mess, thanks to an innovative internal mechanism.

Attracted to the potential reductions in shipping costs and shelf space, Walmart agreed to an exclusive distribution deal, bringing along its partner Berry Plastics to supply the containers.

From Dec. 7-11 representatives of the $100 billion consumer formulated products industry will gather at the Consumer Specialty Products Association Annual Meeting in Ft. Lauderdale, Florida to discuss the future of products used every day, everywhere by everyone. Fisk Johnson, Chairman and CEO of SC Johnson, will speak on his company’s approach to earning consumer trust under an initiative called Greenlist, as well as SC Johnson’s plans to expand ingredient information disclosure on its products.

Leading up to Johnson’s remarks will be more than40 outside speakers exploring the forces affecting the future of consumer products. Doug Stephens, a retail industry futurist and author of “The Retail Revival: Reimagining Business for the New Age of Consumerism” will keynote the event December 7.

The more than 50 different sessions at the meeting are centered on the future of products the CSPA member companies make, the needs of consumers, and the look and demands of the retailers and e-tailers that connect the two.

The formulated products industry’s largest business meeting will also recognize the 100th Anniversary of the trade association that was started in New York by 20 pesticide manufacturers.

The technical and commercial development of plastic aerosols has been ongoing for several years, with the Plastic Aerosol Research Group (PARG), an entity within the Consumer Specialty Products Association (CSPA), taking the lead. PARG has been supported by a long list of suppliers and marketers who see this emerging marketplace as one which will expand the market for pressurized products and essentially make for a “bigger tent”. The thinking here is that the more and varied types of spray packages there are, the more applications there will be in the pressurized product format. This variety will only serve to make the total market for aerosols, now estimated at 14 billion units globally, grow larger.

If new technologies are as sustainable and environmentally friendly as they say, the more the better. Clearly, there is consumer demand for products that are Green and sustainable. In fact, many companies in the aerosol marketplace, suppliers and brand owners alike, endeavor to increase recycling and recyclability of their products, make ingredients transparent for both consumer and environmental health, and are very proud of their sustainability efforts.

It is with all of this in mind that we report on the new air freshener from Method on page 10. Recently launched at Target stores, the Method air freshener is packaged in “100% recycled plastic,” according to the company website. What makes this product of particular interest is the claim the company articulates on its label. The product is said to contain “no dirty propellants”. Also displayed on its collateral material in stores is the phrase “Free of CFCs, dirty propellants and dirty ingredients.”

Method packaging featuring “No Dirty Propellants” message

The fact that all aerosol products have been free of CFCs for the past 35 years aside, Spray was not presented with any evidence supporting these claims in the press materials submitted for review. When we asked Method directly what was so “dirty” about propellants, its PR rep responded that it meant “derived from petroleum”. Is not a plastic bottle, originally, derived from petroleum?

It would surprise few readers to know that aerosol products using propellants are regulated by numerous laws and regulations set down by, among many others, The Federal Hazardous Substances Act (FHSA), The EPA’s Toxic Substances Control Act (TSCA), The Clean Air Act and corresponding state laws and The State of California’s Proposition 65, which requires that products contain warnings if they contain substances known to cause cancer or birth defects.
Many would consider “dirty” a marketing term, which brings us to our point.
New products and new packaging technologies are regularly presented in the pages of Spray. Some consider it a valuable sales tool to gain press support and exposure in this manner and may attribute a product’s success in the marketplace to this favorable publicity. We do, however, apply a standard to every new product that we choose to report on. We present the positive aspects of a new development or, as I learned early on in sales, features and benefits. What Method has chosen to do is disparage other products they compete with rather than promote the positives of an air freshener packaged in plastic and powered by air. We hope the marketers at Method will re-evaluate their strategy and not sell their products at the expense of others in this negative and misleading fashion.

Publisher

]]>http://www.spraytm.com/a-bigger-tent.html/feed0With new regulations on the horizon, is your company in compliance?http://www.spraytm.com/with-new-regulations-on-the-horizon-is-your-company-in-compliance.html
http://www.spraytm.com/with-new-regulations-on-the-horizon-is-your-company-in-compliance.html#commentsSat, 01 Nov 2014 04:12:41 +0000http://www.spraytm.com/?p=7004

CARB

Finally, the Office of Administrative Law (OAL) approved the California Air Resources Board (CARB) Consumer Product regulation on Sept. 17, 2014. This action finalizes the amendments and the U.S. Secretary of State has endorsed the rule. Thus, all amendments are final. This process has taken almost a year. The new volatile organic compound (VOC) limits for some of the Aerosol Specialty Coating categories become effective on Jan. 1, 2015. Make sure that if you have products in this category, you check them for compliance.

Survey

The CARB Consumer Products survey is out and you need to review this document. Anyone that sold consumer products into the state of California in 2013 that are listed in the survey needs to report their product to the state. The deadline to file is March 1, 2015.

CARB had a webinar on its Consumer Products Reporting Tool (CPRT) on Oct. 15 to ask questions on the survey or the CPRT. More on this webinar next month.

On Dec. 15, 2014, the staff will have another webinar. Register for that here. This survey is extremely important, as all information is used for rule making. Therefore, the more accurate the findings, the better.

Enforcement

CARB Enforcement has been busy. In 2013, CARB leveled fines of close to $1.6 million on Consumer Product violations. In the first six months of 2014, CARB has settled fines of $409,000 on Consumer Product violations. Make sure your products are in compliance, as CARB staff is out looking for violations.

SCAQMD

The South Coast Air Quality Management District (SCAQMD) staff hosted a symposium called Assessing & Managing Toxic Risk from Alternative VOC Compounds at SCAQMD Headquarters in Diamond Bar, CA on Oct. 29. Recently, SCAQMD has been faced with a variety of issues regarding the potential toxic risk posed by compounds proposed for exemption.

The symposium included presentations from experts from the regulatory, industrial, academic and environmental communities exploring critical issues from different perspectives. The objective was to provide SCAQMD with expert advice and potential future direction regarding the analysis and mitigation of potential toxic risks associated with alternative VOC compounds.

More on this symposium next month.

SNAP

The U.S. Environmental Protection Agency (EPA) released the proposed amendment to the Significant New Alternative Policy (SNAP) Program. The rule can be found here.

The SNAP amendments focus on the prohibition of HFC 134a in products, including all Consumer Aerosol products. Thus, if you need to maintain the use of HFC 134a in your product, pay close attention to these amendments.

OTC

On Sept. 24, the Ozone Transport Commission (OTC) held a meeting in Washington, D.C. In short, there is no new movement on OTC states. Remember that Utah and New Hampshire adopted the OTC 2014 Model Rule.

and New Hampshire’s Consumer Products amendments become effective January 1, 2015 (http://des.nh.gov/organization/commissioner/legal/rulemaking/documents/env-a4100-adpt-pstd.pdf). Both of these regulations follow the OTC New Model Rule, which as we all know, is modeled off of previous CARB Regulation.

In addition, Utah’s Architectural regulation becomes effective January 1, 2015; this again is the OTC’s New Model Rule.

Green Chemistry

The Dept. of Toxic Substance Control (DTSC) held a workshop to discuss its draft three-year work plan on Sept. 25 in Sacramento, CA. DTSC began the workshop with updates on the current draft priority products. The two that affect our industry are the following:

Several members of the public testified. The fishing industry was well represented, stating there is no proof of any harm to the environment. The non government agencies (NGOs) basically wanted more products sooner. The military wanted an exemption for military use and equipment and two groups wanted food packaging to be included.

A couple of weeks ago I received several phone calls from a number of cosmetic manufacturers that were having issues with certain carriers regarding the marking of limited quantities. There appears to be some confusion with respect to the marking of limited quantities by surface, air and ocean, when the “Y” marking is appropriate and when it isn’t, and what size the limited quantity marking must be.

I thought I would clarify some of these questions and offer example illustrations of limited quantities for various modes of transport.

Limited Quantities

A limited quantity of a hazardous material means the maximum amount of a hazardous material for which there is a specific labeling or packaging exception. Whether or not a hazardous material may be shipped as a limited quantity is dependent upon the following factors: (a) the hazard class and division for the substance or article; (b) the size of the inner receptacle; and, (c) the total gross mass of the completed package.

Only certain classes and divisions of dangerous goods may be offered as limited quantities. For transport by vessel, the International Maritime Dangerous Goods (IMDG) Code prohibits all Packing Group I dangerous goods from being offered as limited quantities. For transport by air, the International Civil Aviation Organization (ICAO) Technical Instructions further restrict limited quantities to only certain classes and divisions in Packing Groups II and III, and further prohibits certain substances within those classes and divisions from being shipped.

Experience has proven that many dangerous goods can be shipped safely in strong outer packaging that is capable of meeting the design, construction and performance tests outlined in the regulatory requirements, but which have not been tested. Thus, limited quantities need not be packaged in expensive UN-performance-oriented packaging that has been tested and marked accordingly. There are also certain economic advantages to shipping a hazardous material as a limited quantity, including reduced hazard communication requirements for surface and ocean transport and an exception from the shipping paper requirements for surface transport. Additionally, many carriers have reduced shipping rates or surcharges for limited quantities compared to fully-regulated dangerous goods shipments.

The maximum quantity permitted per inner receptacle (the immediate form of containment) may differ between modes of transportation. For example, a limited quantity of a flammable aerosol is restricted to 1L per can for surface and ocean transport whereas the same product is further restricted to 500mL when offered by air.

Hazard Communication

Packages containing substances and articles offered as dangerous goods in limited quantities must be properly marked and described on a shipping paper, if the shipping paper is required. However, there are important differences in the marking and labeling requirements for different modes of transportation.

Limited quantities of dangerous goods prepared for surface and ocean transport must be marked with the limited quantity “hollow diamond with black points” marking, whereas packages of limited quantities offered for transport by air must have the “limited quantity Y” marking in addition to the hazard class warning label, proper shipping name and identification number.

Marking Requirements

The square-on-point marking must be durable, legible and of a size relative to the package as to be readily visible. The limited quantity marking must be applied on at least one side or one end of the outer packaging. The width of the border forming the limited quantity marking must be at least 2mm and the minimum dimension of each side must be 100mm unless the package size requires a reduced size marking that must be no less than 50mm on each side.

The top and bottom portions of the square-on-point and the border forming the limited quantity markings must be black and the center white or of a suitable contrasting background and the symbol “Y” must be black and located in the center of the limited quantity marking. Limited quantity markings may use the packaging itself as the contrasting background for the center portion of the marking if the color sufficiently contrasts so that the black border, top and bottom portions of the limited quantity marking, and the “Y” symbol, if applicable, are clearly recognizable.

As an alternative, a packaging may display the limited quantity “Y” mark if the package conforms to authorized substance and article provisions and the inner and outer package quantity limits prescribed in 49 CFR §173.27(f).

An example is shown below:

Size Matters

The limited quantity marking must be 100mm x 100mm; however, a reduced-size marking between 50mm and 100mm may be used in place of a corresponding marking that otherwise conforms to the requirements of the Hazardous Materials Regulations (HMR), which permits use of a reduced-size hazard marking when a package surface is too small or of an irregular shape for a full size marking.

The HMR does not prohibit the placement of a limited quantity marking in an orientation where the square-on-point is located with its flat sides parallel to the sides of the packages. A limited quantity marking that otherwise conforms to the requirements of the HMR may be placed square-on-side when the square-on-point is not practicable if the package surface is too small or of an irregular shape for a full size marking.

However, the square-on-point configuration is the preferred (recommended) method for displaying the limited quantity marking required by the HMR. It is important to note, though, that some carriers and foreign competent authorities may not accept shipments where the limited quantity marking is placed on the package in a square configuration where the sides are parallel to the edge of the box.

The U.S. Dept. of Transportation (DOT) also permits the marking size to be reduced to less than the 100mm per side standard (but not less than 50mm) to the extent necessary to accommodate pre-printing of additional information needed with the limited quantity marking such as bar coded shipping labels.

Hello, everyone. Metal pitting corrosion causes perforation and leaking of spray packages. What is the minimum number of elements needed to initiate corrosion and sustain pitting corrosion of the metals used for spray packaging?

Only two materials are needed for metal corrosion: water and metal. Metals are thermodynamically unstable and prefer to be in the form of more stable metal oxide/hydroxides. I refer to the corrosion product as a mixture of metal oxides and metal hydroxides because water is always present in our environment and water will transform an oxide into a hydroxide.

In addition, water is thermally unstable when in contact with a metal. Water is reduced by electrons from the package metal, which is oxidized (corroded) when electrons from the metal are transferred to water. Hence, water enhances the thermodynamic instability of the spray package metal.

There are two types of structural metals used for spray packages: aluminum and iron. Aluminum is used for traditional aerosol containers and laminated foil packages and iron is used for traditional steel aerosol containers.

The aluminum used for spray packages is actually an aluminum-alloy composed of multiple elements, much like your formula is composed of multiple chemicals. The steel used for spray packages is also an iron-alloy formulated with multiple different elements.

It’s natural to ask how much water is needed when examining the two corrosion equations for aluminum and steel (iron). Let’s use an actual perforation to estimate the amount of water needed to sustain pitting corrosion.

The perforation I have in mind is approximately shaped like a truncated cone and has the following dimensions:

0.23 mm deep (thickness of the steel container metal at the perforation site)

An inside pit diameter of approximately 227 micrometers

An outside pit (perforation) diameter of approximately 57 micrometers

I’ll spare you the algebra. A pit (perforation) with these dimensions would consume approximately:

0.112 milligrams of water with aluminum

0.324 milligrams of water with steel

These amounts of water would correspond to approximately 224 parts per billion (ppb) of water in 500mL of product (formula without propellant) in an aluminum spray package and approximately 648 ppb of water in a steel spray package. In other words, the example perforation needed 224 ppb of water to perforate an aluminum spray package and the same perforation needed 648 ppb of water to perforate a steel spray package (both examples are based on a 500mL product-fill). This is not a lot of water for either metal.

Liquid water is also needed to initiate corrosion. The number of water molecules needed to form liquid water is approximately 90, based solely on thermodynamic considerations.

Other ingredients in your formula could raise or lower the number of water molecules needed to form the liquid water needed to initiate corrosion. The amounts of water calculated above would be needed to sustain the pitting corrosion until it perforated the spray package with the (pit) perforation dimensions used in this calculation.

In other words, a very small amount of water is needed to initiate and sustain corrosion until the spray package is perforated. In addition, the chemical composition, physical form of your spray formula and types of spray package materials determine if corrosion will be initiated, the amount of water needed for corrosion initiation and the amount of water needed to sustain corrosion until perforation occurs.

We would be happy to teach our Elements of Spray Package (Aerosol Container) Corrosion short course at your R&D facility. Contact rustdr@pairodocspro.com or visit www.pairodocspro.com. Please send your questions/comments/suggestions to rustdr@pairodocspro.com. Back articles of Corrosion Corner are available from Spray. Thanks for your interest and I’ll see you in December.

]]>http://www.spraytm.com/what-minimum-materials-are-needed-for-pitting-corrosion.html/feed0Procter & Gamble NA President to step downhttp://www.spraytm.com/procter-gamble-na-president-to-step-down.html
http://www.spraytm.com/procter-gamble-na-president-to-step-down.html#commentsTue, 28 Oct 2014 15:51:21 +0000http://www.spraytm.com/?p=7000Melanie Healey, Procter & Gamble (P&G) President for North America, will step down in June after almost 25 years with the company. Healey started her career in her native Brazil in 1990 as a brand manager for Phebo Soap. She will replaced by Carolyn Tastad, Global Customer Business Development Officer, who has been with P&G since 1983.
]]>http://www.spraytm.com/procter-gamble-na-president-to-step-down.html/feed0P&G to sell off Duracell Batterieshttp://www.spraytm.com/pg-to-sell-off-duracell-batteries.html
http://www.spraytm.com/pg-to-sell-off-duracell-batteries.html#commentsTue, 28 Oct 2014 15:49:07 +0000http://www.spraytm.com/?p=6998Procter & Gamble Co (P&G) said it would sell its Duracell battery business, probably through a split-off into a separate company, as it looks to focus on faster-growing brands.

P&G shares rose about 3 percent as investors shrugged off a marginal fall in quarterly sales and warning that a stronger dollar would significantly hurt revenue and earnings this quarter. A surging U.S. currency, reduces the value of overseas sales when they are translated back into U.S. dollars.

P&G and Colgate-Palmolive Co, which on Friday reported a 17 percent drop in third-quarter profit and lowered its full-year earnings forecast, are the latest companies to be hurt by a stronger dollar.

Emerging markets generate about 50 percent of Colgate’s sales and about 39 percent of P&G’s revenue comes from developing markets.

The world’s No. 1 household products maker said in August it could sell about half of its slow-growing brands in the next two years. Duracell, the world’s No. 1 battery business, was widely considered to be one of the largest assets that P&G was likely to divest.

On a conference call, Chief Financial Officer John Moeller said the company had sold or discontinued 11 brands in the latest quarter and 25 in the last five quarters. Analysts expect it to sell laundry brands Fab and Trojan, Perma Sharp shaving blades and Fekkai hair products, among others.

Demand for Duracell’s mainstay non-rechargeable, disposable alkaline batteries has waned while a worldwide explosion in electronic devices has increased demand for re-chargeable batteries.

P&G, whose brands include Pampers diapers and Tide detergent, said it would first sell its interest in a China-based battery joint venture for an undisclosed amount and then exit Duracell completely.

The company said it was looking to split Duracell off into a stand-alone company but would consider alternatives that offer better value to shareholders.

Under the split-off, expected in the second half of 2015, P&G shareholders would be able to exchange some, none or all of their stock for shares of Duracell.

“The World of Cleaning in One Convenient Place” is the theme of the 89th ACI Convention, which is the cleaning product supply chain’s top business-to-business forum. Nearly 900 business leaders attended the 2014 ACI Convention.

“The ACI Convention provides the best annual opportunity for companies in the cleaning product sector to meet with customers and suppliers at business-to-business meetings, breakfasts, lunches, networking receptions, charity events and on the golf course,” said Ernie Rosenberg, ACI President & CEO. “The value of our Convention is that we have the world of cleaning in one convenient place in Orlando, Florida.”

Convention Week also features meetings of ACI’s expert standing committees, which tackle the major issues confronting the cleaning product supply chain.

In-depth updates of what ACI is doing on its members’ behalf will be provided at the annual ACI Issues Briefing, while leaders of ACI’s counterpart organizations from around the world will speak during the Convention’s Global Industry Update.

S.C. Johnson announced plans to voluntarily identify and disclose to consumers fragrance ingredients used in the company’s air care products.

Labeling guidelines under the FDA’s Food, Drug and Cosmetic (FD&C) Act currently allow manufacturers to use “fragrance” as a blanket term for up to about 50 ingredients. S.C. Johnson will be the first major global company to publicly identify them in its products.

Starting next Spring, consumers will be able to visit a website (WhatsInsideSCJohnson.com) and find, “a range of 10 to 50 fragrance ingredients, on average,” according to a statement from the company. Either the top 10 highest-concentration ingredients, or all ingredients making up at least 0.1% of a product’s formulation, will be made available.

Recent findings suggest that some fragrance ingredients used in consumer products can cause irritation or allergic reactions in users. A 2009 study from the National Environmental Health Association (NEHA) found that 30.5% of Americans experienced some level of skin irritation or headaches when exposed to scented products.

A significant change designed to promote transparency and build consumer trust, the disclosure effort will begin with air care products in the U.S. and Canada before expanding to Europe and then on to other product categories, such as household care.

]]>http://www.spraytm.com/sc-johnson-to-make-fragrance-ingredients-known-to-consumers.html/feed0Aerosol Propellants Safety Seminar – It’s Not Too Late!http://www.spraytm.com/aerosol-propellants-safety-seminar-its-not-too-late.html
http://www.spraytm.com/aerosol-propellants-safety-seminar-its-not-too-late.html#commentsFri, 17 Oct 2014 13:52:16 +0000http://www.spraytm.com/?p=6936It’s not too late to register to attend the Consumer Specialty Products Association (CSPA) Aerosol Propellants Safety Seminar on October 28 at the Chicago Marriott Suites Hotel. The latest draft agenda for the session is attached. And, although the hotel deadline is passed, you can still make reservations at the CSPA rate of $199 by contacting Laura Geib at lgeib@cspa.org.

Aerosol Propellants Safety Seminar

Aerosol Propellants—they’re effective, they’re powerful, they make aerosol products work. But if they’re not handled right, you risk the safety of your employees and success of your business.

Q: So how do you get up to speed on the current best practices for handling and storage, and learn from the experts about leading equipment and techniques?

A: By attending the CSPA Aerosol Propellants Safety Seminar.

The one-day program has been designed with one goal in mind, helping all those who handle aerosol propellants to learn current safety practices from industry experts.

Technological innovations in aerosol and dispensing systems packaging will be recized during the Paris Aerosol & Dispensing Awards, designed to help promote aerosol packaged products, with prizes awarded by an independent jury of brand owners, packaging suppliers and the media. For examples of the 2014 winners, see Spray April 2014, p.22.
The Aerosol & Dispensing Forum is requesting submissions for the 2015 Paris Aerosol & Dispensing Awards. The contest is open to all product areas: Health & Beauty, Household, Pharmaceutical, Food, Technical, Building, Painting, Decorating, Crafts, Gardening, etc.
Products must have been marketed between Jan. 1 and Dec. 31, 2014. To enter, send two product samples per entry, along with an A4 fact sheet including the name of the product(s), its primary innovative characteristics and highlights of technical challenges by Nov. 12, 2014 to:

Submission to the Awards is free of charge. Awards will be presented in February at the Paris Aerosol & Dispensing Forum. Don’t miss this opportunity to have your aerosol technology or innovation internationally recognized. For more information: (+ 33) 1 48 91 89 89, eduperrier@oriex.fr, www.aerosol-forum.com.

In advance of the June 1, 2015 deadline for adoption of the new Globally Harmonized System of Classification and Labeling of Chemicals (GHS)–as mandated by the U.S. Occupational Safety and Health Administration (OSHA)–Croda, Inc. will begin labeling drums and samples in accordance with the new system before the end of 2014.

No products in Croda’s portfolio will change; rather, the system for classifying them will be altered. Croda’s proactive approach is meant to help its customers make the transition as seamless as possible, according to the company. Resources providing information and assistance regarding the change can be found at www.crodausa.com/usghs.

With assistance from the British Aerosol Manufacturers’ Association (BAMA), the Association for Science Education (ASE) has revised the aerosol section of theschoolsciencewebsite moving away from its original textbook style and incorporating bright, attractive photographs, illustrations and videos showing current technology from several BAMA members. Each page has a graded set of questions suitable for pupils and studentsaged 11 to 18.

The refreshed section uses aerosols as a practical case study to teach students about kinetic theory and pressure and includes relevant images and self-test questions where answers are compared with those from the ‘expert sponsors’. Accompanying the website articles is a set of three colourful A3 posters:

Aerosols Explained

Aerosols and Pressure

Aerosol Know-How

The posters include facts about aerosols, an explanation of the inner workings of an aerosol can and all the components and how pressure makes aerosols function. The school posters are distributed free of charge to recipients in the UK and EU. International requests will be required to cover postage. To request your copy, visit www.bama.co.uk/publications

Web resources provide something extra, a different perspective that science based industries and professionals can provide to bring the curriculum to life for their students. As well as free and downloadable curriculum resources, the site also contains information about educational competitions and awards, a full contacts directory, showcases items from educational publishers and suppliers and links to other sites plus Kitpot, the scheme to distribute free equipment, apparatus and publications.

Dr John Morris, Chief Executive BAMA comments: “Bringing to life the science in everyday products stimulates understanding and aims to help both teachers and pupils. It furthers a comprehension between industry and education and we are proud to be part of that process.”

BAMA supports the www.schoolscience.co.uk website that provides free on-line resources linked to the national curriculum for science teachers and students. Managed and administered by ASE. The site is free to use and aims to provide a comprehensive directory of teaching and learning resources, information and contacts for science teachers and their students.

For more information regardingschoolscienceor BAMA’s new posters, contact Amy Falvey at amyfalvey@bama.co.uk.

Over the years, a surprising number of volatile organic compounds (VOCs) have been used as aerosol propellants. Those that are liquids at room temperatures have ranged from n.pentane (-5 psi-g. at 70°F) to carbon dioxide (837 psi-g. at 70°F). Those such as nitrogen, compressed air (CAIR), oxygen and argon have critical temperatures below -310°F. They cannot be liquefied above that cryogenic temperature, even at pressures up to 50,000 psi-g. Around 1965, the aerosol industry arbitrarily decided that volatile compounds boiling above 105°F would be classified as propellants (methylene chloride boils at 103.57°F).

Some exotic propellants have been commercialized in aerosol forms. DuPont’s C-318 (octa-fluorocyclobutane, 25.1 psi-g at 70°F) was once used as a food propellant, always with nitrous oxide. It allowed more product to be used in any given can size. Vinyl chloride (monomer, 34 psi-g. at 70°F) was used around 1960 in paints, hair sprays and shave creams until it was discovered to be a mild animal carcinogen. While no one was harmed, torts were pursued by lawyers for over 30 years. As late as about 1995, non-flammable sulfur hexafluoride (321 psi-g at 70°F) was being used in at least two automotive products. Still later, it was found to have a Global Warming Potential (GWP) of about 25,000, meaning that the escape of one pound into the atmosphere would be the equivalent of injecting 25,000 pounds of carbon dioxide. Ethylene oxide, a flammable sterilant and toxic gas (7.3 psi-g at 70°F) has been packaged in small aerosol containers for use in hospitals and clinics. Similarly, methyl bromide (marginally flammable, 27.9 psi-g at 70°F) has been filled into special Crown cans as a toxic insect fumigant for tomato greenhouses, flour mills and bakeries. It is arguably the most intensive solvent ever put in an aerosol dispenser. It is poured into the bottomless, inverted can after which the base is attached by double seaming, using a special sealing compound. There is no top opening. To operate the unit, a special valve is attached, puncturing the top of the can. Lastly, in the early 1950s, sulfur dioxide (34.4 psi-g at 70°F) was aerosolized as a refrigerant refill. This was a case which the propellant was also the product.

To illustrate the versatility of the aerosol system, laboratory work has shown that perfectly dry solutions of hydrogen chloride (HCl) in petroleum distillates were very effective in removing lime and rust stains from sinks, tubs and toilets, but the odor, toxicity and acidity with water precluded commercialization. Aerosols containing anhydrous ammonia (114 psi-g at 70°F and 317 psi-g at 130°F) were also prepared as a potential coolant additive for early refrigeration systems, but the pressure was excessive. They were never commercialized.

The first aerosol propellant to be banned was vinyl chloride monomer (VCM) in about 1960. This was an industry ban, precluding the need for any government intervention. However, the U.S. Environmental Protection Agency (EPA) and U.S. Food & Drug Administration (FDA) did issue regulations banning chlorofluorocarbon (CFC) propellants in April, 1978 after determining that they could diminish the planet’s stratospheric ozone layer. Europe followed some ten years later, and a few countries were still using CFCs as late as about 2010. The ban included CFCs 11, 12, 113 and 114. Later amendments targeted the Halons, as 1301 and 1211, and the HCFCs, as 22, 142b and 133a. Also included were some “low flammability” solvents, such as alkyl bromides and 1,1,1-trichloroethane. Under its Significant New Aerosol Propellant (SNAP) program, the EPA must approve all new propellants developed for aerosol applications. It not only considers Ozone Depletion Potential (ODP), but tropospheric ozone generation (VOC programs) and GWP, as well. It also reviews these criteria for existing propellants. For example, after a round table meeting on Aug. 1, 2014, centering mainly on the GWP of 1350 for HFC-134a, the EPA is now considering which aerosol applications will still be allowed as of 2016. Health and life safety uses will survive; others will be carefully scrutinized.

The number of propellants available to the industry is still impressive, and during the last two years the list has been increased by the introduction of propellant, having a carbon-to-carbon double bond. Table One will illustrate those currently available.

TABLE ONE

PROPELLANT PRESSURE psi-g 70 F PRESSURE psi-g 130 F. SOLVENCY

Propane 109 257 Poor

Iso-Butane 31.1 97.1 Poor

n-Butane 16.7 67.0 Sl. Better

iso-Pentane -3.5 18. Poor

n.Pentane -5.0 11. Sl. better

Dimethylether (DME) 63. 174.6 Excellent

HFC-134a 70. 199. Fair

HFC-152a 62.6 174.5 Good

HFO-1234yf 87.8 205.9 Good

Solstice HFO-1234ze 45.3 140. Good

Solstice PF 2.2 29. Excellent

Carbon Dioxide 837. n/a. Good

Nitrous Oxide 720. n/a. Good

Nitrogen n/a. n/a. Poor

Compressed Air (CAIR) n/a. n/s. Poor

Oxygen n/a. n/a. Poor

Argon n/a. n/a. V. Poor

NOTE: DuPont’s HFO-1234yf has been developed principally as an air-conditioner coolant.

HFC-134a uses are extremely limited due to its high GWP (also HFC-227ea).

With such a diversity of propellant pressure and solvent abilities, it is apparent that a diversity of gassing machines is currently in use by the aerosol industry. A further distinction relates to production speed, which currently ranges from one-head (laboratory type) models to very complex 18-head models, “boiler-plated” to produce 20 units per head per minute, or 360-per-minute-per-machine.

From the beginning of the aerosol industry in 1947 to about 1958, at least several fillers used the so-called “cold fill” process for adding propellants to cans. The early Crown and Continental cans were delivered to fillers without attached bottoms, to be filled inverted. The concentrate and propellant (sometimes mixed in large pressure tanks) were chilled to -40° to -45°F (-40° to -43°C) and poured into the cans. The can bottoms were then hermetically double seamed on to the body flanges. Hot water bathing followed. When the industry converted to the nominal “one inch” mounting cup valve in 1953, the pre-chilled contents were poured through the hole, valves were inserted by manual “valve pokers”, the cans were sealed by crimping and then hot water bathed.

The “cold fill” process had many shortcomings. The low-odor kerosenes, often used for insecticides and air fresheners, sometimes turned “slushy” at the -40°F temperatures. Water-based products froze and could not be filled. The large HCFC-22 or ammonia based refrigeration system and hot water bath required prodigious amounts of power. Lastly, propellant evaporation, while producing air-free aerosols, was also a significant economic burden.

Fortunately, machines for filling liquid propellants backwards through the valve were developed around 1953 by such firms as Alpha Engineering and Kartridg-Pak. They became known as Through-the-Valve (TTV) gassers. The in-line gassers could be used with up to four heads on a two track, double indexing line, producing as fast as about 80 cans per minute with wide-open valves. The more preferred versions were rotaries, where a standard base machine could be equipped with three, six or nine heads. In operation, the cans would be perfectly placed on platforms and the gassing head would descend so that an adapter would engage the valve stem. A piston would then deliver a fixed volume of liquid propellant into the aerosol can. To properly energize the gasser, the propellant would be delivered at pressure of about 450 to 625 psi-g. This required a special pump to raise the typical pipeline pressure from about 150 psi-g to the desired range. Excessive pressures had to be avoided or they could “dish” depress the flat-bottomed valve mounting cups of those days. A refinement that took a long time before coming into general use was to control the propellant temperature, and thus its density. This could be accomplished with a small heat exchanger. Otherwise, if the propellant slowly warmed up during sunny days, the density would decrease and less weight would be injected into cans. The machine could always be stopped and the cylinder volume re-set, but this would be time consuming.

A major problem with these early TTV gassers was the throughput rate of the aerosol valve. This was most serious when attempting to fill a large quantity of propellant through a valve with a small stem or body tailpiece orifice, such as one with a 0.013″ diameter. The gasser would then become the rate-determining operation of the production line, slowing it down and thus reducing the all-important number of filled cans produced per shift. Product development chemists were advised to concentrate on specifying valves with larger orifices, even though they might deliver the product faster than desired.

UTC Gassing Station. Photo provided by MBC Aerosol.

In these early days, a number of aerosol products utilized carbon dioxide or nitrous oxide. There was even White’s Propellant: a blend of 85% nitrous oxide (“sweet”) and 15% carbon dioxide (“tart”), where the two taste elements cancelled each other out and did not change the sensory properties of natural or synthetic whipped creams. These high pressure propellants were stored in manifolded cylinders or receptacle tanks. Since vapors would be withdrawn, a cooling process, the containers were heated electrically to maintain a pre-set temperature range. At some facilities, cylinders were warmed with hot water. The gas, at pressures of about 130 to 180 psi-g, was then piped to a gasser-shaker machine. Both in-line and (later) rotary designs have been utilized.

In the in-line machines, some 10 to 18 cans (depending upon diameter) are led into a long slot, placing each of them under a gassing head. The heads descend, with adapters depressing the valve stems. Then, gas pressure is applied; at the same time, the machine agitates the cans using a pre-set amplitude, frequency and time. Lower injection pressures are needed to add the desired amount of carbon dioxide or nitrous oxide to low viscosity products, such as windshield de-icers and those containing high levels of petroleum distillates. In the case of cookware lubricants, which contain high levels of relatively viscous vegetable oils, higher injection pressures are needed to adequately achieve the desired amount of propellant. Viscosities are often checked, preferentially by determining the Ostwald Coefficient (Zahn Cup Method, et al.).

The gassed aerosol cans leave the gasser-shaker with various “over-pressures,” typically of about 10 to 50 psi. Further shaking or just standing overnight will cause a pressure reduction to (or close to) the equilibrium value. A little known fact is that the gas injections will increase the content temperature, typically by about 3° to 6°F, depending on the amount absorbed, the specific heat of the product and other factors. After propellant injection, the cans are normally led directly to the hot water bath, where the pressure is raised still further.

The jostling on the conveyor belts and the act of heating both cause some of the “over-pressure” to dwindle.

There are reports of injection pressures as high as 260 psi-g. If this much pressure was actually transmitted into an aerosol can, it would at least become distorted and possibly burst. However, the pressure in the can relates to the rate-limiting orifice size of the valve and to the rate of absorption by the product. Because a given valve specification will produce a rather significant range of delivery rates, it follows that gas injection rates will also be variable. As a general rule, higher injection pressures will result in a wider range of aerosol equilibrium pressures than lower ones.

The solubility of carbon dioxide and nitrous oxide varies considerably, depending on the solvent. In contrast, the solubility of nitrogen and compressed air (CAIR) is almost negligible. At 70°F and 100 psi-g., 100mL of water will dissolve a mere 0.478 g. of the gas. Solubility data in some solvents is now illustrated.

TABLE TWO

Solubility in Various Solvents at 100 psi-g and 70°F

SOLVENT CARBON DIOXIDE (%) NITROUS OXIDE (%)

Water 1.50 0.78

Acetone 12.08 10.21

Ethanol (Anhydrous) 5.57 5.66

Isopropanol 4.7 4.5

Methanal 18.5 17.7

iso-Pentane 5.39 5.38

Petroleum Distillates 3.32 3.52

Vegetable Oils 4.48 4.87

NOTE: Methylal is CH3-O-CH2-O-CH3; a very strong solvent with a sharp odor.

Vegetable oils include corn, canola and soybean oils.

TTV Gassing Station. Photo provided by MBC Aerosol.

Modern Propellant Injection

In the U.S., most liquid propellants are now filled by either TTV or Under-the-Cup (UTC) gassers. The latter machine is available in one-head, rotary nine head or rotary 18-head models. The rotary machines accurately position the aerosol cans (with valves inserted but not crimped) under a complex head and adapter. As the machine turns a partial vacuum of about 18 to 22″ Hg. is first drawn. This is optional. Then the valve mounting cup is mechanically lifted slightly and propellant is added. Finally, the cup is pressed down quite forcefully (download pressure) and the hermetic crimp is performed. These operations contrast with those of the TTV gasser, where the can is first either atmospherically or (partial) vacuum crimped on a separate machine, after which it travels to the gasser for propellant injection. The cost and complexity of the UTC gasser have limited its use in aerosol lines outside the U.S. and Canada. It also leaves a “valve cup full” of liquid propellant when the can is exited. This 3mL or so of propellant instantly evaporates with a unique hissing noise, causing a barely visible cloud of gas to slowly drift downward, where it is captured by the laminar air ventilation system and safely discharged. This may seem insignificant at first, but for a high-speed line producing 100,000 cans per shift, the gas house loss would amount to about 82.2 U.S. gallons.

An early advantage of the UTC process is that the propellant is injected around the valve cup, so that the flow rate is not impeded by valve orifice size. To overcome this deficiency for TTV gassers, male valves and adapters were modified so that valves could be gassed both through and around the stem. This by-passed the stem orifice, but left the body tailpiece and any vapor-tap orifices still in play. Nevertheless, it was a significant step forward and probably led to the sale of more TTV gassers.

During the 1980s, Summit developed a unique valve called “The Super 90” where the top of the nylon body was crenelated (multi-notched or indented—“crowned”). When under about 600 psi-g. of liquistatic pressure in the gasser, special stem gaskets bend downward into these small channels, allowing the propellant to quickly flow over the temporarily deformed gasket and into the can. This development was copied by other valve suppliers and has effectively removed the last flow rate obstacle to the use of TTV gassers. These comparatively simple machines have low maintenance, can operate with Buttons on Valve (BOV) with small actuators, lose relatively little propellant in the aftermath of gassing and have the ability to be operated in unoccupied (TV monitored) gas houses. For both UTC and TTV gassers, when using dimethylether (DME), the hoses must be metal lined or metal mesh covered to prevent static charge build-ups and the gaskets must be DuPont’s Kalrez for continuous service.

Coster Rotary Gassing Equipment

The gassing of carbon dioxide at high speeds has posed some challenges. One marketer fills their hydroalcoholic product by first making a solution of about 10% carbon dioxide and 90% ethanol in a pressure-resistant mixing tank. This mixture, with a pressure of about 200 psi-g. at 70°F, is used as the propellant portion. In about 1995, the Kartridg-Pak firm (now R.A Jones & Co.) developed a nine-head oscillating gasser-shaker, capable of dissolving carbon dioxide into unusually viscous liquids and even flowable pastes. Today, however, most high-speed methods include the IIG process.

This process, developed in about 1980, initially used a UTC gasser to very rapidly inject carbon dioxide, under pressures of about 460 to 680 psi-g, into low viscosity aerosol concentrates. The gas would then explode the liquid into millions of tiny particles, providing a huge surface area, and thus enabling the concentrate to rapidly adsorb the gas. If all went well the cans would leave the gasser with carbon dioxide pressure only 10 to 15% higher than the final equilibrium pressure, which would be attained after a day or so of aging. Each filler has preferred operational parameters, but some guidelines can be given. There should be at least a 25 to 30% volume headspace for good particulation. The carbon dioxide should be tempered to about 100° to 106°F. The concentrate should be equilibrated to about 60°F. Adapters should be used to permit unimpeded (thus instantaneous) flow of gas into the can.

Island depressors may be needed to restrain flat cup valves from flexing upward slightly under unusual conditions, as with tall 211×709 cans of water-based insect sprays.

While TTV gassers have been used for IIG, sometimes, with a can shaking machine immediately afterward to reduce non-equilibrium over-pressures, they can be troublesome unless process conditions are ideal. They must be used with the “Super 90” type valve, but even here the rate of gas injection is thought to be slightly slower than that of UTC gassers. If the gas pressure is a bit too low, then the special rubber stem gasket may not depress fully into the body channels, impeding flow rate and causing reduced particulation of the product. Special stem gaskets with slightly reduced Durometers may be more tolerant of lower injection pressures. Island depressors are recommended to prevent the possible slight upward flexing of flat cup valves, but are not needed for conical cup valves.

In this important rulemaking, PHMSA will define “reverse logistics” for dangerous goods that are intended to be returned to, or between, a vendor, manufacturer, distributor or other person for the purpose of returning for credit, recalling product, replacement or other reasons. PHMSA is proposing to create a new section within the HMR that will provide an exception for certain hazardous materials that are transported in a manner that meets the definition of “reverse logistics.”

PHMSA will clearly identify those hazardous materials that are entitled to the proposed regulatory relief, and will delineate the requirements for packaging, hazard communication, training and segregation applicable to reverse logistics shipments.

Comments on the proposed rule must be received by Oct. 10, 2014.

Current Regulations

Currently, the HMR do not provide any specific exceptions for shipments made in the reverse logistics supply chain. Consequently, all hazardous materials that are being shipped from a retail outlet back to the distribution facility are subject to the same requirements as when they were originally shipped. The retail outlet is responsible for ensuring that the goods are properly marked, labeled, described, packed, packaged, stowed, segregated and declared for transport.

Items that were once classified as consumer commodities that no longer meet that exception;

Undeclared hazardous materials shipped within the stream of commerce;

Properly marked and labeled original packaging being improperly reused to ship returned products that are either not hazardous materials or hazardous materials for which said packaging is not authorized; and

Shipments that are not accompanied by appropriate hazardous communication, such as shipping papers, emergency response numbers, placards, labels, markings and other requirements of the HMR.

This has been very problematic for many retailers, as the condition of the containers prior to return is questionable, and the original packaging, marking and labeling is no longer available in most cases. Given the value of the product being returned for credit, and a general lack of knowledge, many of these hazardous materials have been returned improperly.

Based on extensive research and enforcement actions by the agency, PHMSA has learned that the current requirements applicable to reverse shipments is misunderstood or overlooked. PHMSA believes that reverse logistics issues associated with these dangerous goods will continue to rise with the increased consumption of consumer products in a growing economy. Based on the many petitions submitted by industry trade groups and several big box retailers, PHMSA believes that it would be beneficial to work with industry to facilitate the movement of hazardous materials in the reverse logistics supply chain.

Authorizations

Under the proposed regulations, DOT will define “Reverse Logistics” in 49 CFR §171.8 as “…the process of moving goods from their final destination for the purpose of capturing value, recall, replacement, proper disposal or similar reason.”

PHMSA will create a new section, 49 CFR §173.15– —Reverse Logistics–General Requirements & Exceptions, which authorizes a limited number of hazardous materials, including:

(2) A Class 3, 8, 9, Division 4.1, 5.1, 5.2, 6.1, 6.2 material contained in a packaging having a gross mass or capacity in each inner packaging not exceeding:

(i) 0.5kg or 0.5L for a Packing Group I material;

(ii) 1kg or 1L for a Packing Group II;

(iii) 5kg or 5L for a Packing Group III, or ORM–D material;

(iv) 30L for a diluted mixture, not to exceed 2% concentration, of a Class 3, 8 or 9 material or a Division 6.1 material;

(3) A Division 2.1 or 2.2 material in a cylinder or aerosol container with a gross weight not over 30kg. For the purposes of this section, a cylinder or aerosol container may be assumed to meet the definition of a Division 2.1 or 2.2 materials, respectively, even if the exact pressure is unknown; and

(4) A Division 4.3 material in Packing Group II or III contained in packaging having a gross capacity not exceeding 1L.

PackagingAll packaging must be leak-tight for liquids and gases, sift proof for solids and be securely closed, secured against shifting and protected against damage. All inner packaging must be secured against movement within the outer package and protected against damage under conditions normally incident to transportation. For liquids, the inner packaging must be leak-proof and the outer packaging must contain sufficient absorbent material to absorb the entire contents of the inner packaging. For solids, inner packaging must be sift-proof. In addition, each material must be packaged in the manufacturer’s original packaging, if available, or a packaging of equal or greater strength and integrity. Outer packaging is not required for receptacles (e.g., cans and bottles) that are secured against shifting in cages, carts, bins, boxes or compartments. However, any compromised receptacle must be placed in an inner packaging or outer packing that will prevent spillage in transportation.

Aerosols must be packed to prevent inadvertent discharge of the contents from the aerosol packaging during transport. Each aerosol container must be secured with a cap to protect the valve stem. Other cylinders or pressure vessels containing Division 2.1 or 2.2 materials such as DOT–39 cylinders and cylinders containing limited quantities of compressed gases must conform to the packaging, qualification, maintenance and use requirements of the HMR.

Hazard CommunicationWith respect to the marking and labeling, the outer packaging, other than a cylinder shipped as a single packaging, must be marked with a common name or proper shipping name to identify the hazardous material it contains.

Training
PHMSA will require that each person who offers or transports a hazardous material under the reverse logistics exception must be familiar with the requirements of this 49 CFR §173.157.

Employees that prepare reverse logistics shipments, as defined in 49 CFR §171.8 of the HMR, subject to the exceptions in this new section, are not subject to the training requirements of this subchapter provided:

(1) The employer has identified the hazardous materials subject to the reverse logistics rule, has verified compliance with the appropriate conditions and limitations and has provided training and supervision to persons preparing or offering these shipments for transportation, or transporting shipments in reverse logistics to make the provisions of this rule effective.

(2) The employee has received appropriate training applicable to the material to be offered in transport in accordance with the provisions of this rule. The training must enable the employee to recognize the hazardous materials, identify the hazards associated with the applicable material and prepare the shipment as provided by this section.

(3) The employer must maintain a record of those employees receiving the training required by this section; and

(4) The operator of a motor vehicle that contains a reverse logistics material must be informed of the presence of the hazardous material and must be informed of the requirements of this section.

Other Requirements & ExceptionsReverse logistics materials may be transported by motor vehicle with other hazardous materials without affecting its eligibility for the exceptions provided by this rule.

However, any hazardous materials that may react dangerously with one another may not be transported in the same outer packaging. However, different hazard classes of materials in reverse logistics may be transported in the same cargo transport unit provided that they are adequately separated to prevent commingling of materials that may result in a dangerous reaction in the event of an accidental release during transport.

Shipments made under the Reverse Logistics Exception are subject to the incident reporting requirements in 49 CFR §171.15, but shipments prepared, offered for transportation, or transported under this exception are not subject to any other requirements of the U.S. DOT’s Hazardous Materials Regulations.

For questions regarding this rule, its implementation or impact, or to obtain a copy of the Notice of Proposed Rulemaking, contact the author at steve@shipmate.com or (310) 370-3600.

As of 1/1/2015, the new limits for the California Air Resources Board (CARB) Specialty Coating Categories (B) become effective. There are two points to consider. The first is that the Specialty Coating Categories (B) was “capped” at the highest MIR values reported in the survey. This is key because if you did not report to the survey, your products may not be compliant. Second, you will need to use the 2010 MIR values, not the 2001 values. There are differences in these values.

I suggest that you re-evaluate all your Specialty Coating products using the new values and checking the values against the new effective dates. To do this you will need to go to the CARB website at http://www.arb.ca.gov/regact/2013/cp2013/cp2013.htm. These amendments have not been officially approved by the Office of Administrative Law (OAL) yet, thus arenot in current regulations.

Make sure you check your products before CARB enforcement does. It could be expensive if they find an issue first.

Survey

On Sept. 2, CARB released its 2013 Consumer Products Survey. Any company that sold or supplied products on the survey list into California in 2013 is required to fill out the survey. As stated in earlier articles, this is the most comprehensive survey on Consumer Products to date. I suggest you start by reviewing the list of products and go from there. The survey is due to CARB by March 1, 2015. On Oct. 15, 2014, CARB will hold a webinar on the survey. Review the documents by then. The survey can be found at http://www.arb.ca.gov/consprod/regact/2013surv/2013main.htm.

Regarding rulemaking, the rule is only as good as the information we have to use. Please fill out the survey.

SCAQMD

Rule 1168, Adhesives & Sealants has been postponed. TheSouth Coast Air Quality Management District (SCAQMD) staff is preparing for a symposium on “Assessing and Managing Toxic Risk from Alternative VOC Compounds.” The staff is trying to determine if compounds exempted from the volatile organic compound (VOC) definition by the U.S. Environmental Protection Agency (EPA) can be used in the District. SCAQMD does not automatically exempt compounds exempted by EPA. This should be a very interesting symposium. All types of people will likely be present: regulators, industry, academics and environmentalists. It should be a colorful discussion. Rule 1168 will be back!

SNAP

As reported last month, the EPA released the proposed amendment to the Significant New Alternative Policy (SNAP) Program. The rule can be found at

On Aug. 27, EPA held a hearing on the proposed rule. One hundred and twenty people showed up. Thirty-eight people spoke, but unfortunately, there were only three or four people who spoke on aerosols. Most were from the refrigerant or foam sectors. Only about five people supported the rule. Comments are due by Oct. 6, 2014. The SNAP amendments mainly focus on the prohibition of HFC 134a in products, including all Consumer Aerosol products. Thus if you need to maintain the use of HFC 134a in your product, comment by Oct. 6.

Green Chemistry

The Dept. of Toxic Substance Control (DTSC) is status quo and still working on the Priority Products for its Safer Consumer Products Regulation. The two products that affect our Industry are Spray Foam and Paint Strippers. This process will likely be ongoing for a year or longer. DTSC had proposed two dates to host workshops on their three-year work plan in August, but cancelled them. The workshops will likely be resceduled. This was surprising and frustrating for those of us that planned to attend (and already had plane tickets)!

Hello, everyone. There are essentially up to two phases in a spray package: a liquid phase (could be your product plus the propellant) and a gas phase. Spray packages that use liquid propellants have both phases , while spray packages with internal bags typically only have a liquid phase.

Spray package corrosion could be one of three general types: general corrosion (sometimes referred to as uniform corrosion), localized corrosion and vapor phase corrosion. The different types of corrosion are often referred to as different corrosion mechanisms. I’m going to provide an overview for each of the three mechanisms.

General Corrosion

General corrosion could occur in either the liquid area of the spray package or in the vapor area. In some instances, general corrosion could be in both areas.

General corrosion covers a large area of the spray package interior and removes package metal, coating or laminate film at more or less a uniform rate. General corrosion is typically very slow and does not significantly reduce container and container component service lifetime.

However, general corrosion does contaminate the product with metal ions and these ions could adversely affect product efficacy, such as smell and color.

General corrosion could also cause large areas of coating or laminate delamination from the package base metal. Pieces of free coating could clog spray valves, thus preventing the package from spraying and reducing package service lifetime.

Service lifetimes are defined as the length of time before spray package leaks product or propellant, valves leak propellant or partially full containers no longer spray. In other words, service lifetime is the amount of time during which spray packages and valves function properly.

Localized corrosion

Localized corrosion occurs in very small areas and in occluded areas that restrict diffusion into and out of the area. Localized corrosion is different from general corrosion in the following ways:

Localized corrosion is significantly faster than general corrosion and often reduces service lifetime

Localized corrosion is in a very small area

Localized corrosion occurs in occluded areas such as container seams and laminated bag welds—diffusion into occluded areas is restricted and significantly lower than bulk diffusion

Localized corrosion often needs a large amount of surrounding surface area to support the high rate of this type of corrosion

Localized corrosion could be pitting, crevicing and delamination of coatings and laminate films from the package metal. The most common forms of metal localized corrosion is pitting and corrosion inside the crevices formed by aerosol container double seams and the container curl-aerosol valve crimp area. The most common form of coating and laminate film localized corrosion is blistering.

Vapor phase corrosion

Vapor phase corrosion is typically not found in spray packages with internal bags. It is different from liquid phase corrosion in that it is corrosion under a very thin film of liquid. Estimations of the liquid film thickness are around 30 microns thick.

General and localized corrosion could occur in the vapor area of a spray package. The mechanism for initiating and propagating includes diffusion of corrosive species, such as water, through the thin liquid film to the spray package surface. In liquid phase corrosion, bulk diffusion is part of the mechanism for initiating and propagating the corrosion.

We would be happy to teach our Elements of Spray Package (Aerosol Container) Corrosion short course at your R&D facility. Please contact rustdr@pairodocspro.com or visit www.pairodocspro.com. Please send your questions/comments/suggestions to rustdr@pairodocspro.com. Back issues of Corrosion Corner are available on CD from Spray. Thanks for your interest and I’ll see you in November.

]]>http://www.spraytm.com/what-are-the-various-spray-package-corrosion-mechanisms.html/feed0Robertet completes new HQ in New Jerseyhttp://www.spraytm.com/robertet-completes-new-hq-in-new-jersey.html
http://www.spraytm.com/robertet-completes-new-hq-in-new-jersey.html#commentsMon, 29 Sep 2014 14:05:33 +0000http://www.spraytm.com/?p=6782Robertet, one of the oldest fragrance and flavor companies in the world, has announced the completion of a new fragrance and ingredient division headquarters in Mount Olive, New Jersey.Robertet has a global reach represented in over 50 countries, 14 manufacturing sites on three continents, three R&D innovation centers and 12 creative centers.

“Our newly renovated, beautiful state -of –the- art innovation center has been completely transformed”, stated Christophe Maubert, Global President, Fragrance Division. “Our $20M investment has greatly expanded our production capacity, enhanced our stability and sensory testing and increased our levels of automation. This investment will bring a new level of service to the changing needs of our clients and provide our perfumers with an array of new tools.”

There were sound business strategies behind the investment in Mount Olive explains Robert M. Weinstein, President & Chief Operating Officer, RobertetUSA. “Mount Olive is all about inspiring creativity backed by high-tech support and scientific research to grow our business in the U.S., service our global clients in the natural ingredients space more effectively and make full use of a facility built with the future in mind.”

Robertet’s expansion has also been influenced by consumer behavior. “We know that consumers today have a greater appreciation for natural ingredients and are looking for authenticity in their lifestyle choices.Thanks to our award winning “Seed-To-Scent” (™) technology, Mount Olive will allow us to create even more traceable, sustainable and true-to-nature scents.

“We are very proud to make this significant investment in our future here in the US. With this wonderful new Mount Olive facility and the talented Robertet team who are based here, our future will bloom and prosper”, concluded Maubert.

]]>http://www.spraytm.com/robertet-completes-new-hq-in-new-jersey.html/feed0ACE launches “People Against Inhalants Network”http://www.spraytm.com/ace-launches-people-against-inhalants-network.html
http://www.spraytm.com/ace-launches-people-against-inhalants-network.html#commentsThu, 18 Sep 2014 13:44:25 +0000http://www.spraytm.com/?p=6724The Alliance for Consumer Education (ACE) announces the launch of the People Against Inhalants Network (PAIN). The online community (www.peopleagainstinhalants.com) was developed to bring together parents and families who have lost a loved one to inhalant abuse.

The idea of PAIN was developed by Sgt. Jeff Williams, ACE Board of Trustee and father of Kyle Williams. Mr. Williams’ 14-year-old son died due to inhalant abuse on March 2, 2005. Williams is with the East Cleveland Police Department and his wife is a nurse. The family had a retired police K-9 certified in drug detection living in the home when their son died.

“We had talked to our kids about drugs and alcohol since they were little. Neither my wife nor I thought about or knew anything about inhalants,” said Williams. “I wish we had.”

PAIN’s purpose is to build a community of support for sharing memories and stories about those lost to inhalant abuse. “Although none of us would have chosen to be part of this community, we now share an unfortunate bond,” said Williams. “We welcome others into this community and hope they will help each other get through this pain.”

Users will be able to create a profile in memory of their deceased family members where they can share stories and pictures. Users can also interact with each other through unique features on the website like the Thinking of You Hearts and through private messages.

The Alliance for Consumer Education, which has been dedicated to shedding light on the significant and lasting dangers of inhalant abuse for fourteen years, is funding the project through corporate and individual donations. Visit PAIN at www.peopleagainstinhalants.com.

The Alliance for Consumer Education (ACE) is a 501(c)(3) nonprofit organization founded in 2000. The ACE mission is to promote responsible and beneficial use of products to ensure a safer, healthier and cleaner environment in homes, businesses and the community. ACE is affiliated with the Consumer Specialty Products Association.

Finally, the California Air Resources Board (CARB) staff has submitted the 2013 Board approved amendments to the Office of Administrative Law (OAL). On Aug. 5, 2014 the Final Rulemaking package for the September 2013 Amendments for Consumer Products was filed with OAL, which now has until September 17, 2014 to make a determination on the amendments. After all this time, there is no reason to believe that OAL will have any issues with the amendments. Remember, these amendments have all the new volatile organic compounds (VOC) limits for the Aerosol Coating, some of which are effective 1/1/2015. Therefore, Industry needs to be prepared to meet these limits. Other important amendments dealt with definition changes, such as single purpose degreaser and cleaner, as well as the addition of the HFO-1234ze to the VOC exemption list and the delay in the 10% VOC limit for Multi-purpose Lubricant from 12/31/2015 to 12/31/2018. Hopefully, the rest of the process will move along quickly.

Survey

CARB has been working on refining its next survey. As previously stated, this will be the most comprehensive survey ever for Consumer Products. The number of products surveyed, and the range of information requested, will be more than was ever required in previous surveys. Be prepared to begin working on the survey soon. Sept. 1 is the proposed date for the release of the new survey and a webinar is scheduled for Oct. 15 to answer survey questions and to provide clarification on the survey. Therefore, be sure to review the survey by October 15, 2014. More information will follow.

SCAQMD

Rule 1168, which deals with Adhesives and Sealants in the South Coast Air Quality Management District (SCAQMD), has been put on hold indefinitely. Remember, this is the proposed regulation that was targeting Consumer Products for regulation by the district. Even though this rule is on hold, Industry needs to work with the district and CARB to maintain Consumer Product regulations. SCAQMD will focus on this regulation at a future time.

Currently, staff is preparing for a symposium on assessing and managing toxic risk from alternative VOC compounds, tentatively scheduled for Oct. 29 at SCAQMD.

SNAP

The changes to the Significant New Alternative Policy (SNAP) Program at the U.S. Environmental Protection Agency (EPA) appeared in the Federal Register on Aug 6. You can download the rule here.

These changes affect the use of HFC-134a in most products. Currently, EPA is proposing to prohibit HFC-134a from all Consumer use and a majority of technical uses such as tire inflator, air horns, some duster applications, fire detector testers and more.

Currently, the following products are being allowed to maintain theuse of HFC-134a:

cleaning products for removal of grease, flux and other soils from electrical equipment or electronica; lubricants for electrical equipment or electronics; sprays for aircraft maintenance; pesticides for use near electrical wires, in aircraft, in total release insecticide foggers or in certified organic use pesticides for which EPA has specifically disallowed all other lower-GWP propellants; mold release agents; lubricants and cleaners for spinnerettes for synthetic fabrics; duster sprays specifically for removal of dust from photographic negatives, semiconductor chips and specimens under electron microscopes; document preservation sprays; metered dose inhalers for the treatment of asthma, chronic obstructive pulmonary disease, allergic rhinitis and other diseases where aerosols can be used for systemic delivery through lung, nose or other organs; wound care sprays; topical coolant sprays for pain alleviation; and products for removing bandage adhesives from skin.

On Aug. 1, Industry convened with EPA at a meeting with The U.S. Small Business Administration (SBA) to discuss these proposed changes. We are going to have a difficult time changing this proposal. There was a public hearing on these changes on Aug. 27 in Washington D.C. and the close of comments is on Oct. 6. If you need changes to be made, then your company needs to become involved—now!

Green Chemistry

The Dept. of Toxic Substance Control (DTSC) is still working on the Priority Products for their Safer Consumer Products Regulation. The two products which affect our Industry are Spray Foam and Paint Strippers. This process will likely be ongoing for a year or longer. DTSC will be hosting two workshops for its three-year work plan, the first of which was held Aug. 19 in DTSC’s Cypress office, and the second in the Byron Sher auditorium on Aug. 25.

It will be interesting to see which products are targeted next.

]]>http://www.spraytm.com/carb-survey-and-consumer-products-amendments-snap-and-dtsc-priority-products.html/feed0Hazcom deadline looms…http://www.spraytm.com/hazcom-deadline-looms.html
http://www.spraytm.com/hazcom-deadline-looms.html#commentsTue, 02 Sep 2014 13:54:00 +0000http://www.spraytm.com/?p=6650Summer 2014 was anything but relaxing in the regulatory compliance world. With the June 1, 2015 Hazcom 2012 deadline rapidly approaching, companies are furiously completing Safety Data Sheets (SDS) and updating labels. Preparers of labels and SDS are still struggling with how to interpret the new rule. The U.S. Occupational Safety & Health Administration(OSHA) has provided some assistance with the release of four interpretation letters stemming from requests for interpretations made by the American Petroleum Institute.

Letter A clarifies the combustible dust provisions for labels and SDS with a particular focus on products that do not pose a combustible dust hazard when shipped, but may when they are processed by the end user. It is available here.

Letter B is the long awaited guidance on OSHA’s Hazards Not Otherwise Classified(HNOC) classification. There is some clarity provided, such as the fact that water does not require an HNOC classification due to the fact that hot water may scald, nor does it require an HNOC classification due to water making floors slippery. Unfortunately, there are still a number of remaining questions when it comes to HNOCs. The guidance letter can be found here.

The third letter clarifies the classification of mixtures that contain 1–10% of a Category 1 STOT (Single Target Organ Toxicity) ingredient. The letter lays out the circumstances in which the product can be granted a less severe classification, and can be found here.

The final letter contains information on the classification of petroleum streams, which includes crude oil and anything derived from crude oil, such as butane or propane. For aerosol companies, this is likely the most useful of the four letters and provides guidance on both classification and the information that must be disclosed on a safety data sheet. It can be seen here.

GHS in Canada

Canada is slowly making progress on the Globally Harmonized System of Classification & Labeling of Chemicals(GHS) with Bill C-31, An Act to implement certain provisions of the budget tabled in Parliament on February 11, 2014 and other measures, receiving Royal Assent on June 19, 2014. The bill contains a number of changes to Canada’s Hazardous Products Act that are needed for GHS to be implemented. Expect new regulations to be released in the Canada Gazette, Part I in the next six months that would take effect in June 2015. There will likely be a two- or three-year window for companies to achieve full compliance. As most labor regulations are at the provincial level, every Canadian province and territory will have to update their regulations as well.

The changes to the Hazardous Product Act are themselves important, as they raise the penalties for non-compliance and give the Minister of Health additional powers to protect the public against harmful products. Some of the key changes are as follows:

Record Keeping: Safety Data Sheets, label and other documentation must be retained by the supplier “for six years after the end of the year to which they relate or for any other period that may be prescribed.”

Testing: The Minister of Health can now order, in writing, sellers or importers of products to submit testing data, conduct tests or “compile information relating to the formula, composition, chemical ingredients or hazardous properties of the product, mixture, material or substance, and any other information that the Minister considers necessary” within a specified time frame.

Seizure of Products & Documentation: Inspectors are given the ability to “at any reasonable time enter any place, including a conveyance, in which the inspector has reasonable grounds to believe that an activity regulated under this Act” [is occurring], which includes manufacturers, importers, distributors and retailers. The inspector is granted the authority to “examine or test any product, mixture, material or substance found in the place that the inspector has reasonable grounds to believe is a hazardous product and take samples of it, and examine any other thing that the inspector believes on reasonable grounds is used or is capable of being used for the manufacture, preparation, preservation, packaging, sale, importation or storage of a hazardous product.”

Penalties for Non-Compliance: The maximum penalties for non-compliance are increased by a factor of 3-5 across the board. Those facing a conviction on indictment can receive a maximum penalty of a fine of $5,000,000 and/or a prison term of not more than two years, up from $1,000,000 and six months, respectively.

The full text of Bill C-31 can be found here, and it contains the amendments to the Hazardous Products Act.

We will be keeping a close eye on both the U.S. and Canadian GHS progress. I am cautiously optimistic that in my next article we will have additional U.S. guidance on Hazardous Not Otherwise Classified and new Canadian GHS regulations.

]]>http://www.spraytm.com/hazcom-deadline-looms.html/feed0The Ban Poisinous Additives Act and epoxy coatings for spray packaging, valves on laminated bags and aerosol valveshttp://www.spraytm.com/the-ban-poisinous-additives-act-and-epoxy-coatings-for-spray-packaging-valves-on-laminated-bags-and-aerosol-valves.html
http://www.spraytm.com/the-ban-poisinous-additives-act-and-epoxy-coatings-for-spray-packaging-valves-on-laminated-bags-and-aerosol-valves.html#commentsTue, 02 Sep 2014 13:50:04 +0000http://www.spraytm.com/?p=6648Hello, everyone. In late July, I received a newsletter from one of our affiliate chemical testing laboratories that discussed the Ban Poisonous Additives Act (H.R. 5033) introduced in early July in the U.S. House of Representatives. A companion bill was also introduced in the U.S. Senate.

This is not a new bill. Indeed, the Ban Poisonous Additives Act has been introduced before in 2011 and 2013. In fact, the controversy/discussion over bisphenol A (or BPA) in epoxy resin coatings is multiple decades old (bisphenol A-epoxy has been around since the 1930s).

The epoxy resin coatings used for food containers, spray packages and aerosol valves are manufactured by reacting BPA with epichlorohydrin. Thus, BPA is a major component of spray package and aerosol valve epoxy coatings.

As with all chemical reactions, there are small amounts of residual BPA in the epoxy coating. It has been shown in some instances that some food products leach a small amount of BPA out of the container coating.

The results from a number of toxicological studies using low concentrations have been inconclusive. However, the potential human health implications have caused more discussion and more toxicological studies—along with calls for legislation banning BPA. Indeed, the U.S. Food & Drug Administration (FDA) has banned the use of BPA-epoxy coatings in infant food packaging and there are already a few states that have banned BPA-epoxy coatings in all food containers.

Normally, I don’t discuss legislation because this topic is covered in another column in Spray, however, H.R. 5033 would have a significant impact on spray packaging corrosion if the bill is enacted into law.

There are approximately 100 times more food containers than spray containers manufactured each year. Thus, the bill—if passed—would also probably cause epoxy coatings in spray packages and aerosol valves to be either discontinued or substituted by a different type of coating for the current internal epoxy coatings in spray packaging and on aerosol valves.

Aerosol valves with epoxy coatings are used in both traditional aerosol containers and the laminated foil bags inserted into them. Hence, the impact on our industry would be extensive if H.R. 5033 is passed into law.

Several decades ago, a number of epoxy coatings were developed that did not use BPA as a major component (in response to the BPA controversy). Some of these alternate coatings were water suspensions of non-BPA epoxy resins.

Corrosion testing on these coatings found that corrosion protection efficiency by the non-BPA epoxy coatings was highly variable. It was discovered with the non-BPA epoxy water suspensions that the type of surfactant used and the surface preparation prior to coating had a significant effect on the ability of the non-BPA epoxy coatings to protect the substrate metal from corrosion. Thus, most of these alternate epoxy coatings were found to provide less corrosion protection than the traditional BPA-epoxy coating.

So what happens if H.R. 5033 becomes law and epoxy coatings with BPA are banned from food containers? The result would be a lot of spray package corrosion testing to qualify new types of coatings for traditional aerosol containers, as well as valves on the laminated packages inserted in aerosol containers and aerosol valves that use epoxy coatings for corrosion protection.

Corrosion evaluation could be either electrochemical corrosion testing or long term storage stability testing. Electrochemical tests can be completed in less than 90 days with a high level of confidence when the appropriate test parameters are used to gather the data. Storage tests should be conducted for at least one year before making a decision on the commercial suitability of an alternate coating.

Please send your questions/comments/suggestions to rustdr@pairodocspro.com. Back issues of Corrosion Corner are available on CD from SPRAY. Thanks for your interest and I’ll see you in October.

“You can’t wait for inspiration. You have to go after it with a club.” —Jack London

Club store packaging has many advantages over conventional retail packaging. Many club stores (a large retailer that usually sells a wide variety of merchandise, in which customers are required to buy large, wholesale quantities) require that certain items be “pallet display-ready” or “floor display-ready.” These club stores have created “club pack” packaging requirements, designed to attract the spontaneous shopper, while making it easier for the club store to manage. Club packs use less material, require less handling by employees (thereby reducing the potential for injuries and lowering labor costs) and are environmentally advantageous.

Club stores identify packaging features they believe to be important and then create requirements for their stores. Some club stores want the 40″ dimension of the pallet to face the customer, while others may want a 48″ side of a pallet to be the selling face. In some cases, club stores may indicate that the consumer be able to access the goods from two, three or even four sides of the pallet or floor display.

While there are not as many hazardous materials available in club pack displays as food items and other non-hazardous goods, there is increasing demand by some club stores to provide “club packs” of beauty supplies, home improvement products and other seasonal items that are classified as dangerous goods.

While there are very specific advantages in the ability to provide these types of products in display-ready formats for club stores and big-box retailers, there are also some limitations that you must be aware of. The regulatory requirements of the U.S. Dept. of Transportation’s (DOT) Hazardous Materials Regulations (HMR) in Title 49, Code of Federal Regulations, subchapter C apply to beauty supplies, home improvement products, cleaning chemicals and even certain foodstuffs that meet the definition of a hazardous material.

Packaging Limitations

Aerosol consumer products may be entitled to some regulatory relief if they are packaged as Limited Quantities (LTD QTY) or classified and described as Consumer Commodities, Other Regulated Material (ORM-D). Flammable and non-flammable aerosols may be reclassed as LTD QTY or ORM-D if they are limited to no more than 1000mL (33.8 fl. oz) and packed in strong outer packaging not exceeding 30kg (66 lbs) per case.

However, the provisions of 49 CFR 173.156(b)(2) state that:

The 30 kg (66 pounds) gross weight limitation does not apply to packages of limited quantity materials marked in accordance with §172.315 of this subchapter, or, until December 31, 2020, materials classed and marked as ORM-D and described as a Consumer commodity, as defined in §171.8 of this subchapter, when offered for transportation or transported by highway or rail between a manufacturer, a distribution center and a retail outlet provided …

(i) The inner packagings conform to the quantity limits for inner packagings specified in §§173.150(b), 173.152(b), 173.154(b), 173.155(b), 173.306 (a) and (b), and 173.309(b), as appropriate;

(ii) The inner packagings are packed into corrugated fiberboard trays to prevent them from moving freely;

(iii) The trays are placed in a fiberboard box which is banded and secured to a wooden pallet by metal, fabric or plastic straps to form a single palletized unit;

(iv) The package conforms to the general packaging requirements of subpart B of this part; and

Despite the allowance given in 49 CFR 173.156(b)(2), aerosol club packs would not qualify to be reclassed and described as “LTD QTY” or “ORM-D” because they exceed 250kg (550 lbs) when packaged according to most club store requirements.

Consequently, the aerosol manufacturer or packaging company would have to seek and obtain a DOT Special Permit that would permit the higher weights needed by the club stores and big-box retailers. There are a number of “club pack” permits that aerosol suppliers may become a party to simply by applying and providing the required information (see Spray, April 2013).

One such Special Permit authorizes the shipper to offer up to 550kg (1,200 lbs) of Classes 3, 8, 9, 2.1, 2.2 or 5.1 hazardous materials as limited quantities or Other Regulated Material (ORM-D) by motor vehicle, rail car or cargo vessel, provided that the inner packaging conforms to the applicable regulatory requirements, the inner packaging is packed into trays to prevent movement and the trays are tightly packed into a large fiberboard box which shrouds the display pack. The special permit display packs are then banded and secured to a pallet with metal, fabric or plastic straps to form a single palletized unit. Each shroud is then marked with the DOT Special Permit number and either LTD QTY or Consumer Commodity, ORM-D. All other requirements and exceptions applicable to limited quantities or Consumer Commodities would still apply.

By applying for and obtaining a Special Permit to transport certain hazardous materials including aerosols as club packs in larger quantities, aerosol manufacturers and distributors may be able to offer larger quantities to club stores and other big-box retailers, thereby opening potential markets that they may not have been able to tap into because of the additional restrictions.

If manufacturers do not want to obtain their own special permit or become a party to an existing permit, they may be able to prepare these products through one of several club pack design and packaging firms that are parties to this special permit.

To learn more about obtaining or using a special permit for club packs, aerosol manufacturers are encouraged to contact the author by phone at +1 (310) 370-3600 or by e-mail at steve@shipmate.com.

The EPA Design for the Environment Program (DfE) requires all partner companies to engage in product ingredient disclosure. Earlier this year, Walmart announced that products sold in its stores—including household cleaning, personal care, beauty and cosmetic products—must disclose product ingredients by Jan. 1, 2015. These two initiatives have two things in common: they both incorporate the Consumer Specialty Products Association’s (CSPA) ingredient communications model, and they both recognize the CSPA Consumer Products Ingredients Dictionary as a source for ingredient terminology.

The CSPA released the latest update of its dictionary on July 18. Compiled by consumer product companies, it is the only comprehensive technical reference source for the ingredients used in consumer specialty products­­­.

Walmart announced that products sold in its stores must disclose product ingredients.

The Consumer Product Ingredients Dictionary, Second Edition Third Update helps anyone interested in ingredient disclosure sort out chemical trade names, technical names and ingredient disclosure requirements, making it a vital resource for those engaged in consumer product ingredient communication.

The previous version was an essential reference and tool for R&D and regulatory compliance and the newest version is even more comprehensive: 612 Ingredients used in aerosol products, air care products, antimicrobial products, automotive, cleaning products, polishes and floor maintenance products, and pest management products.

1014 trade names and 2340 technical and other names from 53 suppliers establishing consistent nomenclature that is clear, simple, precise and accurate.

It contains more than 600 pages of information, including ingredient monographs, indices and appendices with information to facilitate ingredient disclosure requirements. Information on ingredient uses, functions, sources, chemical classes, finished products, and other technical and regulatory information, including any and all known Chemical Abstracts Service Registry (CAS) numbers and the Volatile Organic Compound (VOC) status for each ingredient as it relates to consumer product regulations, listed as being VOC, LVP, Partial VOC, Partial LVP, or Non-VOC.

The CSPA Consumer Product Ingredients Dictionary is available for purchase on CSPA’s website under either a single-user license or corporate-use license. In addition, these three key indices are available for free:

Aerosol industry leaders from across the eastern U.S. trekked to Vernon, NJ for the Eastern Aerosol Association’s (EAA) annual Golf Outing on Tuesday, August 5th. Over 50 people attended the all-day event at Crystal Springs Golf Resort, nestled in the quiet rolling hills of northwest New Jersey’s picturesque Kittatinny Valley.

For the second year in a row, the Consumer Aerosol Products Council (CAPCO) will represent the industry at the Resource Recycling Conference at the Hotel New Orleans Riverside in New Orleans, LA, September 15-17.

The conference, a gathering of hundreds of recycling professionals, industry leaders and government officials from across North America, features a trade show, symposiums, lectures, training sessions and organizational meetings. The Steel Recycling Institute and Keep America Beautiful will also be in attendance.

CAPCO is seeking volunteers from the industry to help raise awareness of the benefits of aerosol recycling. The cost of registration is $480. Those interested in attending should contact Hillary VanderBand at hvanderband@aerosolproducts.org.

If you manufacture, store, test or sell aerosol products, then you need to attend the 2014 CSPA Aerosol Fire Codes Webinar.

Why? Because the National Fire Protection Association’s Code 30B on the Manufacture and Storage of Aerosol Products was just updated, and the International Fire Code (IFC) was also modified this year.

What you’ll learn. In 90 minutes, David Fredrickson, an independent expert in fire codes and aerosol products fire protection, will break down the changes to and nuances of NFPA Code 30B and the IFC.

The webinar, moderated by Doug Fratz, of CSPA, will provide a background on how the complex array of fire and building codes work, and it will explore the key changes impacting aerosol manufacture, storage and retail display. Participants will also have ample time for questions and answers.

RSVP: How do you attend? Click here to register. Then block offNov. 4 on your calendar.

Registration Rates: CSPA Members: $100; Nonmembers: $200.

The CSPA Aerosol Fire Codes Webinar is sponsored by the Aerosol Products Division of the Consumer Specialty

Did you know?: NFPA 30B covers fire protection for aerosol product manufacture and mercantile display, as well as warehousing.

The CSPA has been very active over the past two years obtaining needed changes to NFPA Code 30B and the IFC that every aerosol products company needs to know.

Bonus takeaways! Presentations will be sent to participants in advance, allowing ample time to formulate comments and questions prior to the session.

]]>http://www.spraytm.com/cspa-aerosol-propellants-safety-seminars-planned.html/feed0MAA & ACE team up with Schaumburg Boomers on 8/8http://www.spraytm.com/maa-ace-team-up-with-the-schaumburg-boomers-on-88.html
http://www.spraytm.com/maa-ace-team-up-with-the-schaumburg-boomers-on-88.html#commentsMon, 28 Jul 2014 14:05:10 +0000http://www.spraytm.com/?p=6525The Midwest Aerosol Association (MAA) and the Alliance for Consumer Education (ACE) are once again teaming up with the Schaumburg Boomers as they battle the Washington Wild Things on Friday August 8th!

Boomers Baseball is a fun for the whole family experience with the most expensive seats at only $10. Come on out and support MAA and ACE as we bring our message that it is OK TO SPRAY aerosol products.

The stadium opens to fans at 5:30pm and the game is at 6:30pm with Fireworks after the game!

Check out the MAA/ACE kiosk on the stadium concourse where we will interact with fans, distribute anti-huffing literature, invite kids to sign anti-huffing pledges, conduct a coloring contest, pass out trinkets, etc…

Sara Stickley from ACE and Sergeant Jeff Williams will be in attendance. Jeff will:

Give a 2 minute pregame speech to the fans

Throw out the ceremonial first pitch in honor of his son Kyle

Interview during the radio broadcast of the game

After the game fans are able to run the bases…Jeff will high five the runners as they cross home plate

August 8th is Bacon Night and not just because we will have our favorite Cop Jeff Williams in attendance!

The venerable hot water bath (or hot tank) dates all the way back to the beginning of the commercial aerosol industry in 1947. Harry Peterson and other pioneers contacted the Interstate Commerce Commission (ICC—a forerunner of the U.S. Dept. of Transportation [DOT]) to get assurance that the new, lightweight aerosol dispensers could be legally shipped throughout the U.S. ICC advisors, such as Dr. “Bus” Fulton of the Association of American Railroads, became concerned about the ability of the cans to withstand heat during transit without deforming or possibly even bursting. It was suggested that two boxcars filled with aerosols be parked for three days that summer in the Mojave Desert in southern California, with about 200 peripheral cans fitted with thermocouples. The test was completed soon afterward with no cans deformed, and the highest temperature recorded was 126.7°F (52.6°C). A small safety factor was added and this became the basis of the 130°F (54.4°C) testing temperature.

At a meeting of the Aerosol Scientific Committee, Chairman Bill Baleu (Bridgeport Brass, Inc.) introduced an executive from the Mojonnier Co., who had brought along a sketch and mechanical drawing of a hot water testing tank. It had two conveyor lanes with magnetic hold-downs and was about 30′ (9.2m) long. Dr. Fulton approved it on behalf of the ICC. Several early contract fillers used local machine shops to construct versions of the device, adding protective screens, thermostats, multiple hot water inlets, an air drying accessory and some other refinements. Attainment of the 130°F product temperature was confirmed by using short, maximum reading thermometers attached to the valve dip tube by a rubber band.

Starting in 1953, the first water-based aerosols were developed and technicians quickly found that these formulas could not be heated to 130°F by one or two minute immersions in a hot tank. In fact, a fairly viscous starch dispersion only rose by about 14°F in temperature. However, the hydrocarbon propellant layer quickly heated up and produced an internal pressure equal to or greater than the pressure generated by immersing the aerosol for an hour or two in a laboratory constant temperature bath set at 130°F. By this time, the ICC had been replaced by the DOT and the loosely-knit aerosol group had become a division of the (then) CSMA. An industry group went to Washington, D.C. and reviewed the situation with the DOT. A convincing technical report was presented and, after a month or so, the agency revised its regulations to require “heating aerosols to their 130°F equilibrium pressure.”

Originally the hot tank was designed to enable the industry to cull out any permanently deformed or exploded cans. However, during those early days about one to three cans per thousand were found to be leakers. In fact, most fillers had a “salvage man” who would collect leakers, store them in a deep freeze, then puncture them to transfer the costly contents into fresh cans that were sealed and put back on the production line. With the advent of water-based formulas and flammable propellants, this practice was discontinued. Leaking cans were collected in small drums at the end of the hot tank. They were then frequently removed to an outside staging area, often for on-site disposal, along with underweight or overweight aerosols and those with dents, marred lithography or other problems. Fortunately, supplier quality today is extremely high; very few defective cans are detected per shift.

The European aerosol industry became commercial in 1956. The Dangerous Substances (EEC) Directive that describes pressure testing and pressure resistance of cans states that aerosols must be heated to 122°F (50°C). During the 1990s, the DOT was contacted by the European Aerosol Federation (FEA) and the U.N. concerning the harmonization of its testing regulations with those of Europe, and ultimately the world. They reacted by adding an alternative. Aerosols could be heated to develop their equilibrium pressure to 122°F (50°C), provided the content would not fill more than 95% volume of the dispenser when heated to 130°F (54.4°C). Because of legal and labeling concerns, nearly all U.S. marketers have decided to stay with the original 130°F (54.4°C) regulation, although the energy cost is somewhat higher.

As may be anticipated, regulators and the industry have both introduced complexities to the hot tanking process. Certain products that are debilitated by heat are exempted, provided one can in every 2,000 is heated to 130°F without incident. Others that develop pressures as high as 310 psi-g (21.4 bars-g) at 130°F are permitted as aerosols, provided the dispenser carries a pressure-relief fitment. Several Bag-On-Valve (BOV) aerosol products are excused from hot tanking, provided their pressures at ambient temperatures are 100% checked with a can wall deflection device and found to be within a stipulated range. In Germany, the use of rotary machines to determine empty can pressure resistance and filled can seepage rate is approved as an alternative to hot tanking. Regulations related to residence time and seepage rate in hot tanks are under consideration. Plastic aerosols are slowly gaining popularity in the U.S., Europe and Australia and are known in Japan. They will usher in new complexities.

Hot Water Bath Mechanics & Safety
The simplest hot tanks are “dip tanks”—shallow tanks containing water at about 134°F (56.7°C.), into which open mesh trays of several hundred small aerosol cans are immersed for a minute or two. Typical products are metered-dose inhaler (MDI) pharmaceuticals in deep-drawn aluminum #5052 cans ranging from about 16 to 28.5mm in diameter. There is no regulatory requirement to perform this test in the U.S., since the dispensers always have a net capacity well under four fluid ounces (118.3mL).
For larger aerosols (up to the 33.8 fluid ounce or one liter limit), the usual hot tank will be a straight line type, with one to four magnetic rails or conveyor lanes. Lengths can vary from about 12 to 30′ (3.7 to 9.2m)—the smallest ones often used on pilot lines.

Two types of Magnetic Rail Water Baths

The dispensers are normally fully immersed, but a few fillers adjust the hot water level to cover only about the lower 80% of the can. This satisfies the regulatory heating requirement, but if there are any leaks through the top double seam (tinplate cans only), the crimped seal or through the valve, they will not be detected. The rationale is that the high quality of modern cans and valves is such that leaks in these areas will affect fewer than 0.01% of those cans that pass the usual weight-checker and continue through the hot tank.

Since aluminum cans are not affected by magnetic hold-downs, without special arrangements they would fall over on the inclines and also become “floaters.” If they happened to remain near the inlet of very hot make-up water, they could become deformed from excessive internal pressure. One popular solution is to fit a special puck around the bottom of each can. The pucks have a large steel washer in the bottom. The inner wall has a few tangential wing fittings, designed to hold the can firmly, but without marring the surface finish. Pucks are needed for each can diameter. In production, the empty cans are passed through a “pucker” device that attaches the pucks. Later, the finished aerosols go through a “de-pucker” that removes the pucks, after which they are conveyed back to the beginning of the line for recycling.
Alternatively, hot water baths can be purchased where plastic clips fasten to aluminum cans and hold them firmly in place as they pass through the water. They do obstruct visual leak detection to some degree and are still there, however unnecessarily, when the hot tank is used for tinplate or steel cans.

“Clip” Style Universal Aerosol Can Water Bath

A variation of the usual water bath is the serpentine type. Here, the immersed cans will be conveyed about 16′ (4.9m) in one direction, then turned and moved in the opposite direction. This is done three or four times. This longer immersion time is a debatable advantage. The typical 80 square foot (7.4 square meter) footprint makes it the largest of all the machines on most aerosol production lines. An advantage to linear and serpentine water baths is that many have given good service for over half a century.
Another popular hot tank is the rotary or drum style. Aerosol cans are smoothly fed onto a large cylinder in rows of up to 24 or more. The cylinder then rotates to the next empty row. As it turns, cans are immersed in the hot water that covers almost half the wheel. Any leakers are typically daubed in a colored fluid by the operator so that when they are discharged onto the downstream conveyor belt, they can be quickly identified and discarded.

Universal Aerosol Can Material Rotary Style Water Bath

Hot tanks are not without problems. Perhaps the most frequent is a lack of adequate surveillance. Operators are simply not utilized on some filling lines, especially in emerging countries. When they are present, they may be mentally or physically distracted. A gas bubble every three feet (0.92 m.) can equate to a propellant loss of roughly 14 grams per year, yet it will not be detected unless the operator searches the water with a concentrated effort that may be hard to maintain. A recent recommendation has been to change operators every twenty minutes.

Essentially, all U.S. hot tanks are fitted with heavy mesh screens or sturdy clear plastic enclosures to protect personnel in the case of a very rare can explosion. Unless they are used in conjunction with an adequate ventilation system, the plastic may become coated with water condensate droplets and rivulets, frustrating any attempts at detection of leaks other than major ones called gushers or geysers. A ventilation system is a good idea for a number of reasons. If a number of cans were to discharge potentially dangerous amounts of flammable propellant (extremely rare), the system would safely remove it. Secondly, the refuse drum or box near the end of many hot tanks may contain various numbers of leaking dispensers, and these could build up a potentially explosive gas-air mixture. If the hot tank has an exhaust system, it is a simple procedure to install a 4″ (100mm) diameter duct, with an “elephant trunk” and plastic standpipe that will go to the bottom of the waste container and remove any dangerous gas content.

Over the years, several massive hot tank explosions have taken place, usually due to thermostat failure and serious overheating. It is not uncommon for the explosive or brisance effect from one can to cause dozens or even hundreds of surrounding cans to also explode. In one case, many years ago, such an event tore the bottom out of a large hot tank and caused one end to rip through the ceiling of the production room. In another incident, the concentrate valve of an aerosol paint production line was shut off for the lunch break, but not turned back on when production was resumed. The cans went into the hot tank containing only the high pressure (A-85) hydrocarbon propellant. Massive explosions resulted and the hot tank was ruined.

One time, the marketer of an anhydrous hair spray set his hot tank at 152°F (66.7°C) on the premise that the company was giving customers an added modicum of safety. After several years with no problems, an operator noticed a can that was profusely leaking at the side seam. She gripped it with a pair of tongs to remove it from the tank, but it burst, causing a jagged corner of the can body to produce a 10″ slash in her forearm.
Another time, a link in the conveyor belt of a hot water bath separated, causing cans to stop moving. About 100 of those in front of the hot water inlet became deformed as a consequence of bottom reversal. An electrical outage would have produced the same result if very hot inlet water continued to flow into the central portion of the tank. In this case, the marketer installed fairly small water tanks above the hot tanks, fitting each of them with a down-pipe and solenoid valve. In an emergency, the tanks would dump “dousing water” into the hot tank.

Hot water baths should not be shut down when filled with cans. On the same basis they should always be followed by a covered air-blast station to remove water from the valve cup and cans, and then by an accumulating table. The table should be kept fairly empty so that if a downstream problem were to occur, the cans in the hot tank could be smoothly discharged onto the accumulating table, thus preventing overheating. In addition to the thermostat, good engineering would suggest the installation of an excess temperature cut-off device. Some hot tanks are equipped with large dial or digital thermometers. If not, the water temperature can be statistically checked using the usual bi-metallic portable thermometers with 1.5″ (38mm) diameter dials.

Traces of residual water may remain in can/valve crevices, even though the dispensers are air-blasted and allowed a fair amount of time for evaporation. The rust discoloration that may follow on tinplate or steel surfaces can be avoided if the hot tank is kept at about 0.08% levels with corrosion inhibitors. Typically, five gallon (18.92 liters) quantities of either 40% sodium nitrite or 35% sodium benzoate solutions are added at intervals. The amount will depend on the rate at which fresh water is added—or waste water is discharged through standpipes. (Note: The sodium nitrite level can be quickly checked using a standardized potassium permanganate solution. It will be totally decolorized if an adequate amount of sodium nitrite is still present in the tank).

Hot tanks that contain hard water and/or corrosion inhibitors can leave small water droplets on cans. When these evaporate, tiny white spots can be seen, especially on darker lithographed surfaces. By adding as little as 0.015% sodium hexametaphosphate to the water, a streaming drainage action develops that eliminates these droplets.

Hot Water Bath Alternatives
Critics of the hot water bath point to its very large size, water and energy consumption, safety issues, inadequacy to test leakage of heat-sensitive products, issues with manual leak detection and so forth as meriting a paradigmic transition to alternative technologies. In the U.S. the DOT has approved special exemption petitions where BOV nitrosols can be checked for proper pressure by a device that measures the minute deflection of the can body wall when a horizontal force is applied. Deflections are compared with those of a same specification can containing a known pressure. Such lines can avoid the use of a hot tank, although most will have a small one (usually a drum type) for leak detection and a final rinse.

In Europe, a different regimen has emerged. Empty cans are tested on a rotary machine to at least 67% of their design pressure to ensure that they do not deform when filled or leak at a rate of less than 0.033 mbar.liter/sec. Filled cans must be check-weighed so that overfilled cans can be rejected. Finally, another rotary machine is used to briefly enclose all filled cans and reject those that leak at a rate greater than 0.002 mbar.liter/sec. at 68°F (20°C). These steps are required by the road transportation agency Accord European Relatif le Transport International of Dangereuses por Route (ADR), whether the aerosols are hot tanked or tested by alternative means.

The criteria established by the ADR (2007 Section 6.2.4.3.2.2) have been presented to the U.N. Sub-committee of Experts on the Transport of Dangerous Goods. They have supported the regimen, noting that a micro-leak detector would be required on the filling line to assure 100% inspection. These devices, which cost about $10,000, would have to be installed on every line (they are available from Pamasol and other equipment suppliers). While these detectors would work for hydrocarbon detection, provided the air between the water level and sensors is tranquil and not ventilated, it is doubtful that they would work for non-flammable HFC-134a and HFO-1234ze(E), or for water soluble propellants like carbon dioxide and dimethyl ether. They would certainly not work for aerosols pressurized with nitrogen, argon or compressed air.

Through the efforts of the FEA, the EEC Aerosol Dispenser Directive (75/324) has been modified through its Adaptation for Technical Progress (ATP) 2008/47/EC to permit “alternative methods” to hot tanking aerosols. In effect, these documents support the production of aerosols with alternates to hot tanking and their transportation to all EU countries in dispensers carrying the reversed epsilon. The U.S. DOT has now been approached to adopt equivalent regulations in the interest of global harmonization.

In the U.S., serious questions have been raised regarding the maximum leakage rates, such as 0.002 mbar.liter/sec. This standard, while scientifically correct, must be converted to more easily understandable terms to be more useful. The first conversion is that it connotes a seepage rate that would raise the pressure in a one liter container by 0.000002 atmosphere per second. (1.00 bar equals 14.5 psi-gor the average pressure of 1.00 atmosphere at an altitude of about 400 feet.) Considering a 1.00mL container, the pressure gain would be 0.002 atmosphere per second. Similarly, a theoretical 0.002mL container would be pressurized to 1.00 atmosphere—or the gas pressure inside a propellant bubble. This equates to a 0.126mm cube, equal in volume to a 0.134mm diameter bubble. For a hot water bath moving aerosols at 6″ (152mm) per second, one gas bubble 0.134mm or 0.0053″ in diameter would have to be detected every 6″. If a bubble escaped once every 24″ (608mm), at the same seepage rate it would be equal in volume to a 0.200mm cube or a 0.248mm (0.0098″) diameter sphere. Similar calculations can be made to clarify the maximum allowable seepage rate for empty cans in the pressure tester; i.e 0.033 mbar.liter/sec. It is very doubtful if visual observation in hot tanks could reliably detect seepage rates as low as the 0.002 mbar.liter/sec. limit now imposed in Europe. In a specific test conducted recently, only about 8.4 cans per million were found to be leakers. All were slow leakers, passed by a weigh-checker. Considering there are up to 60,000 cans per truckload, that would equate to about one leaker or less in every two truckloads, if not detected in the hot tank or by alternative processes. This is far less than the leakage needed to produce any significant hazard, regardless of propellant selection. The superb transport safety record of U.S. aerosols supports this conclusion, especially since, of the billions of dispensers produced and shipped each year, it is inevitable that some will have been undetected slow leakers.

The Respiratory Drug Delivery (RDD®) Asia 2014 scientific conference will welcome pulmonary and nasal drug delivery experts from all over the world to Goa, India
from November 12-14, 2014. The joint organizers of the first edition of RDD Asia – Aptar Pharma and RDD Online announce the opening of registration. The scientific program and online registration are available at: www.rddonline.com/rddasia2014

Bringing the respiratory world together for the first time in Asia RDD scientific conferences are globally regarded as the premier venue for presenting the latest advances in pulmonary and nasal drug delivery. They take place in Europe (RDD Europe) and the United States (RDD US) in alternate years.

After a successful RDD US 2014 held last month in Fajardo, Puerto Rico, the respiratory world is looking forward to the first RDD Asia meeting, which showcases one of the world’s most prominent emerging markets and a growing location for inhaler and nasal spray development. RDD Asia 2014 seeks to link Asian regulators, industrial and academic scientists, clinicians and business professionals with their international counterparts, together working toward the goal of advancing inhaled and nasal drug therapy worldwide.
RDD Asia, like its predecessors in the US and Europe, will feature lively, fresh and focused updates on respiratory drug delivery in Asia and the rest of the world.
More than 200 delegates from Asia and beyond are expected to attend the conference which will be held at the Goa Marriott Resort & Spa in India. The meeting is jointly managed by RDD Online and Apta Pharma.

Expert speakers will address a blend of contemporary issues and essential background relating to pMDIs, DPIs, nebulizers, nasal sprays and emerging aerosol delivery platforms.
RDD Asia 2014 offers sponsorship opportunities in order to maximize the visibility of organizations throughout the aerosol community months before the conference begins, through the conference website and onsite during the event. In addition, conference sponsors can become exhibitors, providing a unique opportunity to display
their devices, equipment and services, and to interact directly with conference participants. Various levels of sponsorship are available on the conference website (www.rddonline.com/rddasia2014) as well as upon requestat info@rddonline.com

RDD Asia 2014 will also offer several networking opportunities, including a cocktail reception on November 12 and a gala dinner on November 13 sponsored by Aptar Pharma.
Registration op ens for the Respirator y Drug Delivery Asia 2014 scientific conference

]]>http://www.spraytm.com/registration-opens-for-rdd-asia-scientific-conference.html/feed0New AEROBAL website focuses on material aesthetics and qualityhttp://www.spraytm.com/new-aerobal-website-focuses-on-material-aesthetics-and-quality.html
http://www.spraytm.com/new-aerobal-website-focuses-on-material-aesthetics-and-quality.html#commentsWed, 09 Jul 2014 19:33:30 +0000http://www.spraytm.com/?p=6471The design and contents of the new-look website of the International Organization of Aluminum Aerosol Container Manufacturers (AEROBAL) center on the aesthetics and premium nature of aluminum.

“This is because it is the numerous beneficial properties of aluminum that provide that decisive competitive edge over comparative packaging materials,” explained Gregor Spengler, Secretary General of AEROBAL. “And it is the reason why we have focused on these aspects on our new website, not just with regards the contents but visually as well.”

And the result is certainly worth a look. Packaging specialists, product developers, designers, marketing experts, advertising professionals and anyone else who is interested in optimally packaging an aerosol product will find all the important information on the aluminum aerosol can presented briefly and concisely at www.aerobal.org. Contents range from the can’s benefits, such as perfect hygiene, optimal product protection, maximum consumer convenience, and safety and reliability, via the most important markets through to topics such as recycling and sustainability or design opportunities.

Anyone who wishes to find out more or is looking for a leading manufacturer of cans will find the right contact quickly and comfortably anywhere in the world using the AEROBAL list of members. Gregor Spengler describes further objectives of the website: “We are now working on building up a gallery with creative and conspicuously designed alumina aerosol cans. The aim is to demonstrate to interested specialists the fantastic potential of the aluminum aerosol can and provide them with inspiration for their own creative and innovative solutions.”

The Intergovernmental Panel on Climate Change (IPCC) announced its finding that Honeywell’s newly-developed Solstice Propellant (also known as HFO-1234ze) has a global warming potential of less than one, lower than that of carbon dioxide. Solstice was developed as a replacement for high global warming potential and/or ozone depletion potential propellants such as R-12 and HFC-134a, which are currently being phased out by governing bodies across the globe.

The U.S. Food & Drug Administration (FDA) will review Teva Pharmaceuticals’ application for approval of a lower dose of its QNASL aerosol nasal allergy spray to be administered to children ages 4-11. The waterless intranasal spray is currently available for the treatment of seasonal and perennial allergic rhinitis in adults ages 12 and up.

Procter & Gamble will construct a new $89 million, one million square-foot distribution center in Dayton, OH. Providing 800 new jobs, it is one of the largest development projects in the region in a decade. The facility is slated to open its doors in February.

The state of Minnesota banned the use of triclosan in most personal care products, effective January 1, 2017. The chemical is currently used in about 75% of anti-bacterial soaps and body washes marketed in the U.S., according to the U.S. Food & Drug Administration (FDA), but recent studies have raised questions about the substance’s potential to disrupt essential hormones and contribute to harmful dioxins in the environment.

In order to better protect consumers from allergens in fine fragrances, the European Commission announced the introduction of tighter regulations on ingredients and labeling to take effect at the end of the year. Oak moss and tree moss, two popular base notes, as well as HICC, a synthetic molecule that simulates the scent of lilies, will be banned for their allergenic potential. Additionally, the number of possible allergens that must be labeled if present was increased from 26 to more than 80. The commission relented on initial plans for an outright ban on nine other ingredients, including citral, found in lemon oil, and eugenol, from rose oil.

Ashland Specialty Ingredients introduced a new web-based tool to help manufacturers of skin and hair care products identify the preservatives best suitable for specific formulations. Using criteria such as pH range, areas of distribution, product applications and chemistry options, the new tool quickly identifies all preservative options with consideration to regulatory compliance. The tool can be accessed at www.preservativeselector.com.

Symrise announced the establishment of a strategic partnership with two non-profit organizations, the Global Nature Fund (GNF) and the Union for Ethical BioTrade (UEBT), to promote sustainable raw material sourcing and raise awareness of the importance of preserving biodiversity worldwide at every stage of the supply chain.

French personal care brand Yves Rocher announced plans to open 10 stores in Brazil by the end of 2014. The company, which already operates in Brazil through distributors, opened its first store in the largest South American nation last December, in Sao Paulo. A second store in Sao Paulo opened in May, while a third was launched in Rio de Janeiro in June.

The Southern Aerosol Technical Association (SATA) announced that Jim Scalfani, Senior Product Development Manager at Wal-Mart, will serve as keynote speaker at the association’s 2014 Fall Meeting, October 2-5 in Myrtle Beach, SC. Scalfani has held his current postion since 2005 and will speak to attendees about product development from a retailer’s perspective. SPRAY

]]>http://www.spraytm.com/the-latest-headlines-from-the-industry.html/feed0Take a Bath Before You Take a Bath…http://www.spraytm.com/take-a-bath-before-you-take-a-bath.html
http://www.spraytm.com/take-a-bath-before-you-take-a-bath.html#commentsMon, 07 Jul 2014 13:32:08 +0000http://www.spraytm.com/?p=6452Readers are probably already aware that there is a significant difference in how “aerosols” are defined by the U.S. Dept. of Transportation’s (DOT) Pipeline & Hazardous Materials Safety Administration (PHMSA) and the rest of the world. However, just in case, I will highlight this and other differences in the requirements.

Different Definitions

According to Title 49, Code of Federal Regulations, subchapter C, §171.8 an aerosol is:

“…any non-refillable receptacle containing a gas compressed, liquefied or dissolved under pressure, the sole purpose of which is to expel a nonpoisonous (other than a Division 6.1 Packing Group III material) liquid, paste, or powder and fitted with a self-closing release device allowing the contents to be ejected by the gas.”

By contrast, the U.N. Model Regulations, International Maritime Dangerous Goods (IMDG) Code, International Civil Aviation Organization (ICAO) Technical Instructions for the Transport of Dangerous Goods by Air and other regulatory references define an aerosol as:

“non-refillable receptacles meeting the provisions of [the packaging regulations], made of metal, glass or plastics and containing a gas compressed, liquefied or dissolved under pressure, with or without a liquid, paste or powder, and fitted with a release device allowing the contents to be ejected as solid or liquid particles in suspension in a gas, as a foam, paste or powder or in a liquid state or in a gaseous state.”

Consequently, this may present some serious issues when importing or exporting certain compressed gases such as butane cartridges and lighter refills, refrigerants (e.g., 1,1,1,2-tetrafluoroethane) and spray dusters. For example, under the provisions of the IMDG Code, R-134a (1,1,1,2-tetrafluoroethane) may be re-classed and described as UN1950, AEROSOLS, 2.2 and offered as a limited quantity when in metal receptacles of not more than one liter in volume. However, that very same product could NOT be offered as a limited quantity in receptacles between 120–1000mL in the U.S. Title 49 CFR 171.23(b)(1) permits the IMDG Code to be used within the U.S., but specifically requires that compressed gases be limited to 4 fl. oz. (120mL).

Title 49 CFR §171.23(b)(1) states:

“Except for a limited quantity of a compressed gas in a container of not more than four fluid ounces capacity meeting the requirements in § 173.306(a)(1) of this subchapter, the proper shipping name “Aerosol,” UN1950, may be used only for a non-refillable receptacle containing a gas compressed, liquefied, or dissolved under pressure the sole purpose of which is to expel a nonpoisonous (other than Division 6.1, Packing Group III material) liquid, paste, or powder and fitted with a self-closing release device (see § 171.8).”

It is interesting to note, however, that the IMDG Code limits UN3159, 1,1,1,2-TETRAFLUORETHANE, 2.2 to 120mL in order to take advantage of the limited quantities. Although this quantity limitation is consistent with 49 CFR subchapter C, the IMDG Code allows you to reclassify the product as an aerosol, thereby enjoying the “added” volume, whereas 49 CFR does not.

Bath

Another important difference between 49 CFR subchapter C and the international standards, based on the U.N. Model Regulations, is the use of an alternative to the hot water bath test. The IMDG Code, for example, in section 6.2.4.2.2 of the 36th Amendment permits alternative methods which provide an equivalent level of safety, with the approval of the competent authority, and which conform to the requirements outlined in the subsequent sections of the Code.

Provided the requirements of 6.4.2.2.2 are met, and the competent authority has authorized the alternative test method, aerosols outside the U.S. need not be tested in a hot water bath. The requirements include a quality system, pressure and leak testing before filling and testing of the aerosol after filling. For convenience, I have transcribed the requirements below:

Quality system (6.2.4.2.2.1)

Aerosol dispenser fillers and component manufacturers shall have a quality system. The quality system shall implement procedures to ensure that all aerosol dispensers that leak or that are deformed are rejected and not offered for transport. The quality system shall include:

a) a description of the organizational structure and responsibilities;

b) the relevant inspection and test, quality control, quality assurance and process operation instructions that will be used;

d) management reviews to ensure the effective operation of the quality system;

e) a process for control of documents and their revision;

f) a means for control of non-conforming aerosol dispensers;

g) training programs and qualification procedures for relevant personnel; and

h) procedures to ensure that there is no damage to the final product.

An initial audit and periodic audits shall be conducted to the satisfaction of the competent authority. These audits shall ensure the approved system is and remains adequate and efficient. Any proposed changes to the approved system shall be notified to the competent authority in advance.

Pressure and leak testing of aerosol dispensers before filling (6.2.4.2.2.2)

Every empty aerosol dispenser shall be subjected to a pressure equal to or in excess of the maximum expected in the filled aerosol dispensers at 55°C (50°C if the liquid phase does not exceed 95% of the capacity of the receptacle at 50°C). This shall be at least two-thirds of the design pressure of the aerosol dispenser. If any aerosol dispenser shows evidence of leakage at a rate equal to or greater than 3.3 x 10-2 mbar·L·s-1 at the test pressure, distortion or other defect, it shall be rejected.

Testing of the aerosol dispensers after filling (6.2.4.2.2.3)

Prior to filling, the filler shall ensure that the crimping equipment is set appropriately and the specified propellant is used. Each filled aerosol dispenser shall be weighed and leak tested. The leak detection equipment shall be sufficiently sensitive to detect at least a leak rate of 2.0 x 10-3 mbar·L·s-1 at 20°C. Any filled aerosol dispenser which shows evidence of leakage, deformation or excessive mass shall be rejected.

Special Permits Required

In order to avoid the hot water bath test (for other than certain foodstuffs and certain non-flammable aerosols in plastics receptacles), the filler or manufacturer must apply for and obtain a DOT Special Permit, which can be quite a daunting task (see Spray, April 2013). Special Permit applicants must be able to demonstrate an equivalency of safety and will generally be denied a permit based on a “leveling of the playing field” approach.

It is important that you can demonstrate that the methods, procedures and equipment used in pre-filling and post-filling testing will satisfy the DOT’s safety concerns.

Shippers, fillers and manufacturers are strongly cautioned to ensure that they review the U.S. rules very carefully and confirm that aerosols have been subjected to and pass the hot water bath test, or an alternative method has been approved and documented in a DOT Special Permit, which is generally required to travel with the other shipping documents and/or be marked on the aerosol packaging.

Failure to comply with these provisions will subject inbound loads to forfeiture and/or destruction and significant penalties, which can be in the tens or even hundreds of thousands of dollars. Additionally, import shipments that do not conform to the U.S. standards for aerosols because they have either not been subjected to the hot water bath and/or do not meet the U.S. definition of aerosols may be subjected to additional penalties because the required marks and labels or documents, for example, reflect the change in classification and are not appropriate for transport within the U.S. as aerosols.

If you have any questions regarding the testing or transportation requirements for aerosols, contact the author at steve@shipmate.com or (310) 370-3600.

]]>http://www.spraytm.com/take-a-bath-before-you-take-a-bath.html/feed0The Multiple Roles of Water in the Corrosion of Spray Package Materialshttp://www.spraytm.com/the-multiple-roles-of-water-in-the-corrosion-of-spray-package-materials.html
http://www.spraytm.com/the-multiple-roles-of-water-in-the-corrosion-of-spray-package-materials.html#commentsMon, 07 Jul 2014 13:29:40 +0000http://www.spraytm.com/?p=6450Hello, everyone. Water plays many different roles in the corrosion of spray package materials. For example, water molecules:

Could be a corrosive formula ingredient

Transport corrosive formula ingredients to the package metal

Move ionic charges to and from a corrosion site to maintain electrical charge balance

Provide hydroxyl ions that react with metal ions to form visible corrosion (i.e., the rust observed on steel

aerosol containers or the white and black corrosion on aluminum)

Migrate through package polymer coatings and laminate films to the underlying metal and cause metal corrosion and/or delaminate a coating or a laminate film from the package metal (e.g., coating blisters)

Transform container coatings into semi-permeable membranes that allow only specific formula ingredients to migrate through a coating or a laminate film to the substrate metal; and cause metal corrosion under the coating or film

Form microscopic rivers of formula ingredients

in a container coating or laminate film that could subsequently cause coating delamination and/or metal pitting corrosion

Are a solvent for the various corrosion inhibitors used to prevent and control spray package corrosion

Could transform non-corrosive anhydrous formulas into package-eaters

Water could simultaneously play more than one of these roles during spray package corrosion. For example, water is involved in the pitting corrosion of tinplated steel corrosion as follows:

Water reacts with aluminum dissolved in steel to form an aluminum hydroxide gel layer on top the steel container surface (aluminum is added to molten steel during the steel making process)

The water-saturated aluminum hydroxide gel is a semipermeable membrane that allows only water and specific ions to move through the gel

Iron pitting corrosion initiates under the gel in an effort to make the chemical composition of the liquid under the gel the same composition as your formula

Electrons generated by corrosion inside a pit move through the metal and reduce water on the metal surface surrounding the gel. These electrons also reduce electrochemically active ions and molecules from your formula

Water hydrates iron ions inside the pit (under the gel)

and buffers the liquid inside a pit to a pH of approximately four

Some of the hydrated iron ions in the pit will diffuse outside it and through the gel into your formula

Water transports hydroxyl ions from the outside edge of the gel to the hydrated iron ions diffusing through the gel—forming the red/brown rust seen on steel containers
Osmotic pressure inside the pit pulls negative ions, such as chloride ions, and water into and through the gel to continue the pitting corrosion process—until the pit perforates your spray package

Stages Three through Eight typically occur concurrently instead of in a series. This example illustrates how water performs the many roles of
a) creating a corrosive environment
b) initiating pitting corrosion
c) being a transport media for the molecules and the ions involved in corrosion
d) balancing electrical charge
e) forming visible rust

Water needs to be in the liquid state to perform its various corrosion roles. How many water molecules are needed to form liquid water? From a thermodynamic perspective, it only requires around 90 water molecules to form liquid water. However, water is consumed in steps Four and Six. Consequently, more than 90 water molecules are needed to sustain corrosion.

In addition, measurements of water layer thickness in vapor areas indicate that corrosion occurs under a thin layer of water that is approximately 30 water molecules thick. In other words, not a lot of water is needed for spray package corrosion.
Want to learn more about spray package corrosion? We would be happy to teach our Elements of Spray Package (Aerosol Container) Corrosion short course at your R&D facility. Please contact rustdr@pairodocspro.com or visit www.pairodocspro.com. Please send your questions/comments/suggestions to rustdr@pairodocspro.com. Back issues of Corrosion Corner are available from Spray. Thanks for your interest and I’ll see you in August. Spray

]]>http://www.spraytm.com/the-multiple-roles-of-water-in-the-corrosion-of-spray-package-materials.html/feed0CARB, SCAQMD and Environmental Regulationshttp://www.spraytm.com/carb-scaqmd-and-environmental-regulations-2.html
http://www.spraytm.com/carb-scaqmd-and-environmental-regulations-2.html#commentsMon, 07 Jul 2014 13:26:46 +0000http://www.spraytm.com/?p=6448CARB
The California Air Resources Board (CARB) September 2013 Amendments are still not finalized by CARB staff. The 15-day comment period has come and gone. CARB staff has indicated that the amendments will be finalized soon. Therefore, we will just need to wait for the staff to finalize these amendments, which include limit changes and definition changes. Some of the volatile organic compound (VOC) limits are effective on 1/1/2015 for Aerosol Coatings.

Survey
CARB staff is proposing to release a very comprehensive survey on all categories of Consumer Products. CARB held a workshop in May concerning survey details. There were numerous Industry comments on the survey design and information requested. One of the largest issues was the security of this confidential information located in one spot. In addition, the staff is asking for information on all products. Very little grouping is allowed. Thus, all color and fragrance variations of our products will need to be reported. Also, all compounds need to be reported down to 0.1%. These are just some of the changes.
Lastly, staff is requesting that all information be reported electronically using a program that some industry members are finding hard to access.
CARB has proposed that the next workshop will be in early July, but no notice of the workshop has been released as we go to print. CARB wants to release this survey in August. Industry is requesting a delay until later in the year or possibly next year.

Green Chemistry
The Dept. of Toxic Substance Control (DTSC) finished its three workshops on its Priority Product list on June 4. DTSC has proposed the following Priority Products and Candidate Chemicals:
Spray Polyurethane Foam (SPF) Systems containing unreacted diisocyanates
Children’s Foam Padded Sleeping Products containing Tris (1,3-dichloro-2-propyl)
phosphate or TDCPP
Paint and Varnish Strippers and Surface Cleaners with methylene chloride
DTSC had high attendance at the two workshops I attended. The Spray Foam Industry was out in force on this issue. The DTSC asked interesting questions concerning the use and magnitude of products sold. One would think that DTSC would know this information already before picking these products as Priority Products. DTSC had requested all information be sent to them before June 30, 2014.
This will be a long process, as DTSC is to finalize these priority products by October of this year. The process will likely take a year to finalize after that. Following, companies affected will need to begin to produce Alternative Assessments (AA) on their products. These AA could be very expensive to produce. The next step is to submit comments.

SCAQMD
South Coast Air Quality Management District (SCAQMD) is still working on Rule 1168–Adhesives and Sealants. Rule amendments currently proposed would adversely affect any consumer use of Adhesives and Sealants that do not have a CARB VOC limit. In addition, this will set a very bad precedent for the future. The Western Aerosol Information Bureau (WAIB) and National Aerosol Association (NAA) are actively working in the state of California with SCAQMD, CARB and the California Legislature to maintain the regulation of Consumer Products with CARB as statewide rules. This is a very important issue. Statewide Consumer Product rules are essential for the Industry.
In addition, SCAQMD is proposing amendments to two new regulations: Rule 1151 on Automotive Refinish Coatings and Rule 1113 on Architectural Coatings. The good news here is that Aerosol Coatings can only be regulated by CARB. That is California state law!

EPA
The U.S. Environmental Protection Agency (EPA) continues to move forward on amendments to its Significant New Alternatives Policy (SNAP) program. Amendments will include delisting HFC-134a from aerosol use. Industry is working with EPA to develop a definition for Technical Aerosols, which will need to maintain the use of HFC-134a for the foreseeable future.
EPA has sent its proposed rule to the Office of Management & Budget (OMB); after a review, the EPA can propose the rule to the public. Therefore, time is short to get comments in before the rule is released; it could be proposed this month. SPRAY

Hello, everyone. Internal coatings in spray packages are not barriers between the package metal and your formula. Laminate films on metals are typically much thicker than coatings. However, laminate films are also not true barriers between the metal and your formula.

The typical ranges of thicknesses for spray package coatings and laminate films are:

On the order of 300 microns for laminated tinplated steel aerosol valves

On the order of 100 microns for polymer films on the laminated foils for internal bags in spray packaging

On the order of 20 microns for the laminate films on tin-free-steel containers

Coatings are applied to spray package metals and metal foils as:

A separate polymer film bonded to the metal or the metal foil

Various modified versions of epoxy that are thermally cured

Powder spray coatings that are heat treated after application

Polymer dissolved in a solvent that is subsequently heated to remove the solvent (referred to as lacquers)

There are a variety of types of coating and laminate film corrosion:

Wet adhesion loss

Pitting corrosion causes blisters

General corrosion causes blisters

Filliform corrosion

Let’s briefly discuss each form of coating/film corrosion.

Wet adhesion loss causes the coating to delaminate from the substrate metal

Figure 1: Wet adhesion loss

Figure 1 provides an example of wet adhesion loss of a coating. Water and formula ingredients diffuse into and through the coating. Accumulation of liquid at the coating-metal interface breaks the coating-bonds, resulting in delamination of the coating from the metal.

Typically, no corrosion is observed with this type of coating corrosion. The orifices in spray package valves are small and loose of pieces coating could prevent a package from spraying if the pieces clog valve orifices or dip tubes.

Click on images for full-size view.

Pitting corrosion causes blisters

Figure 2: Blistering from pitting corrosion

Figure 2 provides an example of pitting corrosion that causes coating blisters. The area under the blister could either fill with gas from the pitting corrosion or gas from corrosion and liquid that diffuses through the coating into the blister.

Pitting corrosion as shown in Figure 2 typically leads to the leaking of liquid product or gaseous propellant.

General corrosion causes blisters

Figure 3: Blistering caused by metal oxide corrosion product

Figure 3 provides an example of blisters caused by general corrosion under the coating. The corrosion process draws liquid through the coating to the metal-coating interface and breaks the metal-coating bonds. The metal oxide produced by corrosion lifts the coating away from the metal to form the blister, as seen in Figure 3.

Filliform corrosion

Figure 4: Filliform corrosion

Figure 4 provides an example of filliform corrosion. Filliform corrosion is similar to blistering caused by metal oxide corrosion product.

Filliform corrosion is rare, and is usually found in the vapor areas of the container. The metal oxide produced by corrosion tunnels under the coating in the form of small meandering ribbons, as shown in Figure 4.

Want to learn more about spray package corrosion? We would be happy to teach our 1 ½ day Elements of Spray Package (Aerosol Container) Corrosion short course at your R&D facility. Please contact me at rustdr@pairodocspro.com if you would like us to teach this course at your facility. Please also visit our website www.pairodocspro.com for more information about Pair O Docs® Professionals.

Your questions/comments/suggestions for Corrosion Corner are always welcome. Please send them to me at rustdr@pairodocspro.com. Thanks for reading Corrosion Corner and I’ll see you in July.

Please contact Spray Technology and Marketing for back issues of Corrosion Corner on CD.

]]>http://www.spraytm.com/when-spray-package-internal-coatings-and-laminate-films-corrode.html/feed0The Only Constant with GHS is Changehttp://www.spraytm.com/the-only-constant-with-ghs-is-change.html
http://www.spraytm.com/the-only-constant-with-ghs-is-change.html#commentsSun, 01 Jun 2014 04:02:53 +0000http://www.spraytm.com/?p=6190
After months of waiting, Canada is moving again on implementing the Globally Harmonized System of Classification & Labeling of Chemicals (GHS). It is still months away from having a final version of the Controlled Products Regulations in place, but much closer than it was even two months ago. There were significant references to GHS in both the federal budget, which was released on February 11, and the budget Implementation Act, which was introduced for first reading in the House of Commons on March 28.
The February 11 budget document is available for download at: http://www.budget.gc.ca/2014/home-accueil-eng.html. It contains a number of references to chemical regulations, including this section on regulatory cooperation between Canada and the U.S.:

Broad progress has been made in implementing commitments from the Canada-U.S. 2011 Regulatory Cooperation Council Action Plan, with initiatives addressing four main regulated sectors: agriculture and food, transportation, health and personal care products, and the environment. Examples of progress include alignment of a number of vehicle safety standards, joint reviews of pesticides and veterinary drugs, use of the Globally Harmonized System of Classification and Labeling of Chemicals and the development of a common electronic submission gateway for pharmaceutical products.

I recently asked a senior government official what the future may hold for GHS-based regulatory cooperation between Canada and the U.S. He indicated that there is room for “tighter” cooperation in the future, which may occur when both countries modify their respective GHS regulations as new revisions of the GHS guide, known as the Purple Book, are released. These may include, but are not limited to, joint comment periods (where a company could send one set of comments in, simultaneously, to both sets of regulators) and harmonized release dates for regulations. The government official stressed that this would not mean that the regulations would be wholly harmonized as each country has unique issues that they would need to address in regulation. However, when there were differences in regulations, it would be a deliberate act because of circumstances unique to the country, not because regulators did not consult each other during the regulatory process. I am cautiously optimistic that this will mean tighter harmonization of regulations in the future and not just for safety data sheets (SDS) and workplace labels.

In Canada, the first budget document contains information on the government’s priorities for the upcoming year. The actual nuts and bolts are contained in the budget implementation act. This act, known as Bill C-31 (to implement certain provisions of the budget tabled in parliament on February 11, 2014 and other measures) contains amendments to the existing Hazardous Products Act, as well as Canada’s Hazardous Materials Information Review Act, that will be necessary to fully implement GHS in Canada.

Bill C-31 can be downloaded here: http://goo.gl/u07wdv. It includes the following changes to the Hazardous Products Act:

Tightening the loopholes around when a product is considered “for sale.” The new rules are explicit that products “whether for consideration or not” (which includes free samples) fall under the Act.

The supplier requirements are altered to indicate that the supplier is required to provide product labels and SDS for products that are used, handled or stored in Canadian workplaces.

Fines for non-compliance are increased to a maximum of CAD$5,000,000 and/or imprisonment of not more than two years.

The changes to the Hazardous Materials Information Review Act in Bill C-31 are needed in order to implement GHS, but do not appear to place any new burdens on suppliers. The Canadian government estimates that the adoption of GHS will save nearly CAD$400 million through “increased productivity and decreased health and safety costs.”

Expect Bill C-31 to pass before Parliament’s summer break, which starts on June 21. There are still additional steps that need to be taken before GHS is implemented in Canada. The provincial governments as well as the three Canadian territories need to amend their labor laws, as most workplaces fall under provincial, not federal, jurisdiction. The final version of the Controlled Products Regulations needs to be released by Health Canada, as well.

I know many in the industry are worried that Canada will try to impose the U.S. Occupational Safety & Health Administration’s (OSHA) June 2015 full compliance date for GHS. Such fears are unwarranted. The Canadian government has committed to implementing GHS by June 1, 2015, but this would be the start, not the end, of the compliance window. Expect at least a two-year phase in period, which would mean that your Canadian workplace labels and SDS will not need to be compliant until 2017 at the earliest.

GHS will not be a “set it and forget it” process, as there will be more regulatory changes after 2017. Expect both U.S. and Canadian regulations to be updated, as the United Nations issues new revisions every 24 months. There is also a strong possibility that both the U.S. Consumer Product Safety Commission (CPSC) and Health Canada will eventually alter consumer product regulations to a GHS-based system. The only constant with the Globally Harmonized System is change.

What is the GHS?

The GHS is an acronym for The Globally Harmonized System of Classification and Labeling of Chemicals.

The GHS is a system for standardizing and harmonizing the classification and labeling of chemicals. It is a logical and comprehensive approach to:

Defining health, physical and environmental hazards of chemicals

Creating classification processes that use available data on chemicals for comparison with the defined hazard criteria

Communicating hazard information, as well as protective measures, on labels and Safety Data Sheets (SDS)

Many countries already have regulatory systems in place for these types of requirements. These systems may be similar in content and approach, but their differences are significant enough to require multiple classifications, labels and safety data sheets for the same product when marketed in different countries, or even in the same country when parts of the life cycle are covered by different regulatory authorities. This leads to inconsistent protection for those potentially exposed to the chemicals, as well as creating extensive regulatory burdens on companies producing chemicals. For example, in the United States (U.S.) there are requirements for classification and labelling of chemicals for the Consumer Product Safety Commission, the Department of Transportation, the Environmental Protection Agency, and the Occupational Safety and Health Administration (OSHA).

The GHS itself is not a regulation or a standard. The GHS Document (referred to as “The Purple Book”) establishes agreed hazard classification and communication provisions with explanatory information on how to apply the system. The elements in the GHS supply a mechanism to meet the basic requirement of any hazard communication system, which is to decide if the chemical product produced and/or supplied is hazardous and to prepare a label and/or Safety Data Sheet as appropriate. Regulatory authorities in countries adopting the GHS will thus take the agreed criteria and provisions, and implement them through their own regulatory process and procedures rather than simply incorporating the text of the GHS into their national requirements. The GHS Document thus provides countries with the regulatory building blocks to develop or modify existing national programs that address classification of hazards and transmittal of information about those hazards and associated protective measures. This helps to ensure the safe use of chemicals as they move through the product life cycle from “cradle to grave.”

]]>http://www.spraytm.com/the-only-constant-with-ghs-is-change.html/feed0Safety First: Developing Eyes and Earshttp://www.spraytm.com/safety-first-developing-eyes-and-ears.html
http://www.spraytm.com/safety-first-developing-eyes-and-ears.html#commentsSun, 01 Jun 2014 04:02:50 +0000http://www.spraytm.com/?p=6195I recently read that the U.S. Occupational Safety & Health Administration (OSHA) was filing suit against a major telecom company for disciplining several employees after they submitted complaints about hazardous working conditions or filed claims for injuries sustained on the job. As I read the article, I wondered aloud how the culture within this company had become so strained that: (1) the company took these types of actions against its own employees; (2) the employees reported these issues to OSHA, rather than reporting them to the company first; and (3) if the employees did report these safety issues to the company first, the company didn’t take swift and decisive action before the situation deteriorated to the present point.

This assumes, of course, that there are no underlying issues, such as wage disputes, that are being masked under the guise of safety. Legitimate or not, any complaints regarding safety and compliance should be taken seriously. Companies should strive to develop a culture of mutual respect and understanding and set aside their differences when it comes to safety and regulatory compliance. Companies are encouraged to develop eyes and ears at all levels to help promote the well-being and safety of all persons in the workplace.

Shared Responsibility
Safety and compliance is a shared responsibility. Although OSHA mandates in the General Duty Clause that employers must “…furnish to each of his employees employment and a place of employment which are free from recognized hazards that are causing or are likely to cause death or serious physical harm to his employees,” employees have a responsibility to make management aware of hazardous conditions or non-compliance issues that may have arisen and gone unnoticed.

Employees need to help management provide a safe working environment by actively participating in safety and compliance program development, collectively developing and attending the required training, participating in audits and reviews and, in short, becoming the company’s eyes and ears. It is foolish on the part of corporate management to assume that input from the rank and file is not needed or should not be given equal consideration. Likewise, it is foolish on the part of employees to assume that they are not, in large measure, responsible for their own safety or regulatory compliance.

With respect to the transport of dangerous goods, the U.S. Dept. of Transportation (DOT) prescribes penalties under 49 CFR §171.1(g) for

…each person who knowingly violates a requirement of the Federal hazardous material transportation law, an order issued under Federal hazardous material transportation law, subchapter A of this chapter, or a special permit or approval issued under subchapter A or C of this chapter [and] is liable for a civil penalty of not more than $75,000 for each violation, except the maximum civil penalty is $175,000 if the violation results in death, serious illness or severe injury to any person or substantial destruction of property.

A “person” is defined in 49 CFR §171.8 as

…an individual, corporation, company, association, firm, partnership, society, joint stock company; or a government, Indian Tribe, or authority of a government or Tribe, that offers a hazardous material for transportation in commerce, transports a hazardous material to support a commercial enterprise, or designs, manufactures, fabricates, inspects, marks, maintains, reconditions, repairs, or tests a package, container, or packaging component that is represented, marked, certified, or sold as qualified for use in transporting hazardous material in commerce.

However, it is important to note that civil penalties are very rarely assessed against an individual who is acting in good faith on behalf of a company or corporation. In most cases, civil penalty action is taken against the company or corporation responsible for the violation of the Hazardous Materials Regulations (HMR).

Personal & Professional Responsibility
I’ve found that those companies that have the best compliance and safety records foster a culture in which there is a deeply engrained sense of personal and professional responsibility and corporate management and employees are committed to their own safety, the safety of others in the workplace and compliance with regulatory requirements.

In every case, employees are empowered to halt production or withhold shipments of dangerous goods if there is any unsafe act or process or if packages of dangerous goods are not in full compliance with regulatory requirements or corporate policies. Equally true is the fact that these companies have developed and implemented highly effective policies, procedures and training programs with the assistance of employees at every level. These companies also freely share their ideas with suppliers as well as competitors and participate actively in non-governmental organizations and trade associations. These companies continually look for opportunities to further refine and improve their programs (see also Topics in Transportation in Spray, May 2013).

Because employees, supervisors and managers each receive initial and frequent recurrent training on various safety, environmental management and hazardous materials transportation-related topics, the collective workforce has become quite adept at identifying hazards and non-compliant situations and recognizing trends that could lead to an accident or incident. It’s no wonder that these companies are among the most efficient and successful in the world and every facility is extremely clean and well-managed.

Based on my many observations, there seems to be a direct correlation between the cleanliness and organization of a facility and the company’s level of compliance. Invariably, these facilities have developed and implemented a housekeeping plan whereby one or more persons are assigned to, and held accountable for, housekeeping or other duties in a specific work area, laboratory or warehouse aisle. For example, the responsible employee’s photo is posted in a work area and others are directed to contact that person if the conditions are less than ideal.

Recommendations
Companies are strongly advised to think creatively and find ways to develop and foster a safety and compliance culture based on a deep and true commitment to the collective safety. This change in culture begins with management and requires input from employees at all levels.

Companies are encouraged to, with the assistance of safety or management review committees (made up of employees at every level) and/or consultants, conduct a baseline review of the organization’s safety and compliance programs, training needs and methods and processes whereby employers and employees communicate safety and compliance concerns and requirements to one another. Most importantly, companies should implement methods and processes for communicating regulatory and policy requirements in a timely and efficient manner and for receiving feedback from persons at all levels of the organization. Organizations should give careful consideration to all safety concerns and allow them to be freely expressed without fear of reprisal or sanction. Likewise, employees should be encouraged to express these concerns in a responsible manner and offer reasonable suggestions for improvement.

All employees should receive detailed training and instruction and be empowered to make safety and compliance-related reports or decisions that could halt or slow production or shipping schedules. Training should be developed and reviewed by employees at every level within the company to ensure that the training is relevant, efficient and makes sense. In addition, companies are encouraged to offer training more frequently, and in smaller doses, to ensure that the training is more efficient and employees are not overwhelmed by the amount of information provided.

Companies should encourage employees throughout the organization to actively participate in the development and delivery of internal and external compliance reviews, audits and investigations so that there is transparency and a deeper sense of ownership of the process and results. Companies that follow these approaches are almost certainly going to develop a cadre of safety and compliance advocates—the eyes and ears needed to improve productivity, foster goodwill and reduce the potential for costly injuries, accidents or penalties for non-compliance.

For a list of additional suggestions and ideas, contact the author at 310-370-3600 or refer to previous editions of Topics in Transportation in Spray.

]]>http://www.spraytm.com/safety-first-developing-eyes-and-ears.html/feed0CARB, Environmental News, and a Dangerous Precedent from SCAQMDhttp://www.spraytm.com/carb-environmental-news-and-a-dangerous-precedent-from-scaqmd.html
http://www.spraytm.com/carb-environmental-news-and-a-dangerous-precedent-from-scaqmd.html#commentsThu, 01 May 2014 04:22:01 +0000http://www.spraytm.com/?p=6073CARB
Finally, the California Air Resources Board (CARB) has released its 15-day changes to the amendments from the September 2013 board hearing. The changes can be found at http://www.arb.ca.gov/regact/2013/cp2013/cp2013.htm and include modifications made to some definitions and test methods. Please review all the double underlined changes, as these are the ones that CARB will accept comments on. As expected, the staff made some changes to the Single Purpose Cleaner and Degreaser definitions. They changed the word “or” to “and.” Therefore, the definition reads “a product that is designed and labeled…”
The next change was to clarify that product categories that already have an existing volatile organic compound (VOC) category limit are not eligible for this definition. For example, there already exists a VOC category limit for Brake Cleaners, so you cannot label your product as solely a “Brake Cleaner” and think that the product is not regulated. This definition was intended for products that have a sole function and are not part of general purpose or multi-purpose product categories. These are the type of products the Industry thinks of as “Specialty Products.”
I suggest everyone review the changes to determine how these changes may affect their company.
Comments needed to be submitted to CARB by April 18 and hopefully readers saw this notification on Spray’s website. If you are reading it here for the first time, you will notice the deadline has passed.

Surveys
CARB staff is planning a comprehensive survey for 2014 and is hopeful that data for the new survey can be collected electronically.
This survey will be more comprehensive than past ones and staff is proposing that there will be no grouping of products, LVPs or fragrances. Therefore, this survey may take more time to complete than past surveys.
We need to work closely with CARB to make sure all information requested is useful. The timing of the survey’s release is still up in the air. CARB staff would like to release the survey by Summer; however, I believe Industry will need more time to review and comment on the draft survey proposal. Fall is a more likely time for the survey to be released.

SCAQMD
As reported last month, South Coast Air Quality Management District (SCAQMD) is working on amending two rules. The first is Rule 1168: Adhesives and Sealants. This is the first time SCAQMD staff is adding that all uses of Consumer Product Adhesives and Sealants not previously regulated by CARB be regulated by this rule. This is an absolutely horrible precedent for the Consumer Product Industry. The rule is moving forward and is to be adopted in June 2014 if it stays on track.
The second to be amended is Rule 102 with the addition of HFO-1233zd to the list of exempt Solvents. If this amendment is adopted, HFO-1233zd will be VOC exempt from District rules. This rule is scheduled for adoption in May 2014.

OTC
The Ozone Transport Commission (OTC) will hold its next meeting in Washington, DC on May 10. We will see if there is an update from the U.S. Environmental Protection Agency (EPA) on the Consumer Product Rule at that time.

EPA
Remember, the EPA will be looking into its significant New Alternatives Policy Program this Summer. The EPA is proposing delisting several HFCs, namely HFC 134a in Consumer Aerosols, but allowing HFC 134a to be used in Technical Aerosols. Industry is currently working on the definition of a Technical Aerosol. If you have any suggestions for definitions, forward your comments to me.

Green Chemistry
On March 13, the Department of Toxic Substance Control (DTSC) released the initial Priority Products list and candidate chemicals. A Priority Product is a consumer product that contains one or more chemicals known as Candidate Chemicals that have a hazard trait that can harm people or the environment. This initial Priority Products list is the first set of product chemical combinations to be named for consideration by DTSC to be regulated under the Safer Consumer Products regulations. Publication of this draft list of products imposes no new regulatory requirements on manufacturers until DTSC finalizes it by adopting regulations.

Finalizing the initial Priority Products list could take up to two years and the proposed initial list will be finalized with the adoption of regulations for each Priority Product. Prior to initiating formal rulemaking, DTSC will hold public workshops on the proposed Priority Products; the rulemaking process may take up to one year. The first workshop is scheduled for May 7 in Sacramento, CA.

]]>http://www.spraytm.com/carb-environmental-news-and-a-dangerous-precedent-from-scaqmd.html/feed0Storage Tests & “Surprise” Corrosionhttp://www.spraytm.com/storage-tests-surprise-corrosion.html
http://www.spraytm.com/storage-tests-surprise-corrosion.html#commentsThu, 01 May 2014 04:19:37 +0000http://www.spraytm.com/?p=6071Hello everyone. I used the two most difficult questions to answer about spray package corrosion as the title for this Corrosion Corner. An example for the first “Why” challenge is: you have a static storage test on a new formula or line extension, and you open twelve unlined tinplated steel aerosol containers after 12 months and you find 11 clean containers and one container with deep pitting corrosion on the bottom?

The lack of corrosion in all storage test containers is perplexing because a) formula in the containers is from the same pilot plant/lab/production batch, b) the containers were manufactured on the same day and c) the containers were all filled on the same day.

The second “Why” question arises whenever a product-package system suddenly has a corrosion issue after being produced for years without a problem.

In the March 2013 edition of Corrosion Corner, I discussed the microscopic causes for the inconsistency of corrosion found in packages from storage stability tests. This month, we expand the March 2013 discussion to include “surprise” corrosion in commercial products and apparent contradictions among two or more separate storage tests on the same product-package system.

Variability is the culprit that causes the apparent corrosion inconsistency between multiple storage tests on the same product-package system and the sudden appearance of corrosion in a previously corrosion-free commercial product. There are three types of spray package variability: variability within each individual package—referred to as within-package variability; variability within an individual production batch—referred to as within-lot variability; and lot-to-lot variability between different production batches (lots) and repeat individual storage tests on the same package-formula system.

In my experience, variability of package metal chemistry does not usually have a significant effect on spray package corrosion. Consequently, variations in metal chemical composition are not included in the above list.

These four factors could cause corrosion either alone or in combination with one another. The number of combined factors could be very large. For example, there are 24 possible combinations of the four factors for traditional metal aerosol containers.

The relationship between variability factors and the apparent inconsistency of container corrosion may include the following:

Product chemical composition

Small changes in chemical composition, such as pH, fragrance concentration or amount of water, could transform a benign formula into a package-eater. Variability is exacerbated by lot-to-lot variations in raw materials. There are also chemistry differences and variations in raw materials from different sources, even when the specifications for the different sources is nominally the same.

Laminate films and coatings have variable thickness on individual packages, on packages within the same lot and on packages from different lots. Variability in the metal cleaning process and the coating application process could also produce small, susceptible areas on individual package surfaces that lead to delamination and corrosion under the film or coating. Coatings from different sources could also produce a narrower or wider range of thicknesses, even when the specifications for the two sources are identical.

Laminate/coating chemical composition

Variations in the chemistry of laminate films and coatings could cause variability in how the coating adheres to the substrate metal. Variability in adherence could cause laminate/coating delamination with subsequent corrosion under the coating.

Crevice depth to diameter/width ratios

Spray package crevices formed by valve-crimps, double seams and laminated foil welds will be filled with product via capillary action and osmosis. However, not all crevices are created equal. Some have a large opening with a small length while; some have a small opening with a large length and so on.

The ratio of the crevice opening to its length determines whether corrosion will occur inside the crevice and if the corrosion will be general or pitting corrosion. The chemical compositions of formulas also determine how a given crevice ratio and a given formula composition interact to make a crevice more or less vulnerable to corrosion. In other words, there are two variable quantities interacting—composition and ratio—that determine when crevice corrosion will occur.

There are a range of crevice ratios within individual production lots and between different production lots. Hence, crevice corrosion—with or without pitting—does not occur in all spray packages unless the product is extremely corrosive.

There are two ways to account for variability when conducting corrosion tests:

Generate a database on how variability affects package corrosion for each product family in your line of spray products.

Design your corrosion tests to include:

A large number of replicate samples for each variable

Variables with package components from different production lots

Variables with different concentration of potential corrosion-causing formula ingredients, such as water

The corrosion test could be a storage test, an electrochemical test or a combination of both.

Want to learn more about spray package corrosion? We would be happy to teach our Elements of Spray Package (Aerosol Container) Corrosion short course at your R&D facility. Please contact rustdr@pairodocspro.com or visit www.pairodocspro.com. Please send your questions/comments/suggestions to rustdr@pairodocspro.com. Back issues of Corrosion Corner are available on CD from Spray. Thanks for your interest and I’ll see you in June.

In March, “Team Cobalt” visited DS Containers of Batavia, IL to receive a check to sponsor them to travel to Anaheim, CA, to compete in the 2014 VEX Robotics World Championship. In the past, Team Cobalt, whose members also live in Batavia, won First Place in Software Programming Skills and came in tenth in the World Competition. Team Cobalt consists of two 12th graders, Mia Garbaccio and Sue Park and two 8th graders, Katie Miller and Gabby Garbaccio. Gene Garbaccio, father of two team members, is their coach. The slogan “DS Containers, the Shape of the Future,” will be affixed to Team Cobalt’s competing robot.

At the DS Containers plant, the team was provided with an overview of the company’s manufacturing process and a tour of the plant with special emphasis on the robots used to convert flat steel into finished, printed aerosol cans.

Harry Richard Black, the artist who created Mr. Clean, the bald character in a white T-shirt and gold earring featured in P&G product advertisements for more than 50 years, died March 30 at the age of 92. Born in Philadelphia, Black’s artistic career included a 20-year commission from the U.S Dept. the Interior to paint Smokey Bear, the fire prevention mascot who warns us that “only you can prevent wildfires.”

The Evo Oil Sprayer for everyday use in cooking was a winner at the recent third annual International Housewares Association (IHA) Innovation Awards at the McCormickCenter in Chicago. Evo is the first trigger sprayer for spraying cooking oils, according to the manufacturer Delta Industries. Evo Oil Sprayer exhibited at the corresponding International Home + Housewares Show with Harold Import Co., exclusive distributor of Evo in the U.S. Packaging for Evo is supplied by M&H Plastics.

Hillary VanderBand, CAPCO

In recognition of National Inhalants & Poisons Awareness Week, the Alliance for Consumer Education (ACE) hosted a Health & Safety Fair at a local Boys & Girls Club in Alexandria, VA to help children and families learn how to make smart decisions in their homes. The Consumer Aerosol Products Council (CAPCO) participated in the event with a “Recycling Relay Race,” where students had to race to properly place articles in recycling or trash bins. Pictured, CAPCO’s Hillary VanderBand encourages recycling and increases awareness of the recyclability of empty aerosol products.

Stainless steel is the least visible of all packaging materials, but is used in all types of spray packaging. Stainless steel is used to fabricate the springs in spray package valves and the check balls in some types of valves.

Figure 1 shows a cutaway of a spray package valve. The cutting process slightly distorted the spring, which would not normally be so affected.

The most common type of stainless steel is 304 (UNS S30400), which is composed of 18% chromium and 8% nickel in the alloy; trace amounts of other alloying elements (e.g., carbon) with iron making up the balance. In other words, stainless steel is an iron alloy with chromium and nickel as the major alloying elements.

The presence of chromium and nickel in stainless steel gives this iron alloy a unique surface property—the ability to form a very thin, complex chromium oxide/nickel oxide barrier layer or film. This oxide film protects the underlying metal from corrosion by a wide variety of environments, such as consumer formulas.

Please note that the steel alloys and aluminum alloys also used to fabricate spray packages do not have the requisite amount of chromium and nickel in them. Consequently, spray package steel alloys and aluminum alloys do not form a protective surface barrier film of chromium oxide with nickel oxide.

The mechanism by which corrosion and pitting corrosion attacks stainless steel is significantly different from the mechanism for corrosion of other spray package materials. There are several competing theories on how stainless steel pitting corrosion occurs. Each theory has its merits, but the ion exchange mechanism is the most plausible theory to this author.

Halogen ions, such as chloride ions, are more electronegative than the oxygen ions in the chromium-nickel oxide barrier film on stainless steel. Consequently, halogen ions are able to displace the oxygen ions in the oxide barrier film and form chromium halogen/nickel halogen complexes.

These metal ion halogen complexes are water soluble and thus removed from the barrier film by dissolution in the formula water or contaminant water. Removal of portions of the film causes localized damage to it. However, the film is able to repair itself as long as the rate of repair is greater than the rate of damage and other chemicals in the environment, such as low pH (i.e., a large number of hydrogen ions) does not prevent the film from repairing itself.

Stainless steel pitting corrosion initiates and propagates when the damage by halogen ions exceeds the rate at which the film is repaired, causing holes in the film that develop into pitting corrosion.

The mechanism for stainless steel corrosion by halogen ions has somehow been erroneously applied to the steel and aluminum alloys used for spray packages. However, the halogen mechanism is not applicable to these two alloys because they do not form chromium-oxide/nickel-oxide surface barrier films.

In addition, the steel alloys used for spray packaging contain amounts of chromium and nickel to control grain size and prevent the surface of the steel from looking like an orange peel. However, the amount of chromium and nickel in these steels is significantly below the 12% minimum needed to form the protective barrier oxide found on stainless steels.

I have observed a few instances in which valve springs corroded and broke when exposed to low pH formulas. However, the instances of valve spring corrosion and failure with other consumer products have been rare, making stainless steel the material of choice for valve springs.

I advise removing and inspecting valve springs during storage stability corrosion tests, just to be on the safe side. Inspection of valve springs should not add a significant amount of time to a normal corrosion examination. Electrochemical corrosion tests can also be used to confirm that the stainless steel valve springs are not corroded by a given formula.

Want to learn more about spray package corrosion? We would be happy to teach our Elements of Spray Package (Aerosol Container) Corrosion short course at your R&D facility. Please contact rustdr@pairodocspro.com or visit www.pairodocspro.com. Please send your questions/comments/suggestions to rustdr@pairodocspro.com. Back issues of Corrosion Corner are available on CD from ST&M. Thanks for your interest and I’ll see you in May.

News from the California Air Resources Board (CARB) is that its 15-day comment notice will have expired by the end of March. By the time you’re reading this, you will have hopefully seen the comments. Remember, CARB needs to complete work on the 15-day comment notice to finalize the September 2013 Board Meeting amendments. It appears that some changes will be made to the definitions adopted in the September 2013 Board Meeting. If changes are deemed “significant,” CARB staff needs to take the changes back to its Executive Board to be voted on. Hopefully, we will see the changes soon.

In the past, CARB Enforcement has honored any changes made at the Board Meeting that are pending final approval by the Office of Administrative Law (OAL). Be prepared to review and remark quickly on the CARB comments when they become available, as we will only have 15 days to comment.

Next on CARB’s agenda are surveys. This year, CARB plans to survey Architectural Coatings, Personal Care Products and Consumer Products. CARB is in the process of updating its volatile organic compound (VOC) inventory. These surveys will be comprehensive and we need to work closely with CARB on what information is needed and the timing of these surveys. Industry is already involved with several issues that will make completing the surveys in a timely manner difficult.

SCAQMD

The staff of South Coast Air Quality Management District (SCAQMD) is working on amending two rules. First, as reported last month, is Rule 1168. SCAQMD is proposing to reduce the VOC limit in numerous categories, but more importantly it is proposing to regulate all consumer uses of Adhesives and Sealants that do not have a CARB VOC limit. CARB has reviewed several Adhesive and Sealant categories and have not set VOC limits due to technological and commercial feasibility issues. This does not mean that CARB has not regulated these product categories. More discussion with SCAQMD and CARB is needed on this issue.

Second, SCAQMD staff is proposing a change to Rule 102 that will add HFO 1233zd to the list of exempt solvents. In February, SCAQMD held a workshop on this issue. This HFO will likely be used in the degreasing products arena.

OTC

The Ozone Transport Commission (OTC) will hold its next meeting on April 10 in Washington, DC. Industry needs to monitor the OTC for upcoming adoptions of the states with the new OTC model Consumer Products regulation. Timing and consistency maintenance are needed when additional states begin to adopt the model rule.

EPA

The U.S. Environmental Protection Agency’s (EPA) aerosol coating regulation requires triennial reporting, and we needed to report by March 31, 2014. If you missed that deadline, then file as soon as possible. The link to the rule can be found at: http://www.ecfr.gov/cgi-bin/text-idx?SID=0d32f0b120222d0d1e336170b76165a0&node=40:6.0.1.1.7.5.6.12&rgn=div8

Green Chemistry

The product categories and compounds to be regulated by California’s Safer Consumer Products Regulation (Green Chemistry) are due to be released in April 2014 and will be reported on in the May issue of Spray, as well as on www.spraytm.com.

has been with the company for more than 25 years and was promoted to Managing Director. Baksh has been involved in the packaging industry for 38 years, first with CCL Custom Manufacturing (BOV Development), Revlon, EP Spray and Lindal Global. He has spent the past 22 years working with bag-on-valve (BOV) pressurized packaging technology and will play a leading role in the set up and operation of B.O.V. Solutions’ new, state-of-the-art BOV packaging facility dedicated to food production.

The Estée Lauder Cos., Inc. named Guillaume Jesel its inaugural Senior VP/General Manager, Global Corporate Innovation. Jesel was formerly Senior VP, Global and North American Marketing for Estée Lauder’s MAC Cosmetics division. He has been with the company for 14 years. Estée Lauder also promoted Chris Good to President, UK and Ireland and Sandra Main to Global Brand President, La Mer.

Bell Flavors & Fragrances appointed Marvel Fields Senior Perfumer. She previously worked for both Mane and Fragrance Resources. Fabio Azevedo was appointed Senior Account Director for Fragrances. He comes to Bell from IFF. Kelli Heinz was promoted to Director Of Marketing & Industry Affairs.

Avon Products, Inc. hired Nilesh Patel as Senior VP & President, Asia Pacific Region. He joins the company following a 26-year career with the Heinz Co.

Lombardo

Weinstein

Simons

Peter Lombardo, President of Robertet Flavors USA, announced his retirement. An honoree of the International Fragrance Association’s Eric Bruell Distinguished Service Award, Lombardo’s career in the industry spanned five decades. In the wake of Lombardo’s retirement, current COO Robert Weinstein was promoted to President. John Simons was promoted to Senior VP. Both joined the company in 2012.

Joshi

Russell

AzkoNobel promoted Himesh Joshi to the position of Sales Manager, Personal Care for Europe, the Middle East, India and Africa. Prior to the promotion, Joshi managed AzkoNobel’s Surface Chemistry operations in India. Michael Russell was promoted to Technical Service Manager, Skin Care/Sun Care.

DSM Nutritional Products appointed Wilfrid Gambade to the position of Senior VP, in charge of the company’s Personal Care Business Unit. Gambade previously worked at Ciba Specialty Chemicals and Huntsman before joining Royal DSM in 2009. He will replace Ilona Haaijer, who has accepted a different but yet-unannounced position at the company.

Haaijer

Gambade

Karen Daskow was named Director, Consumer Products, Market Research division of Kline & Co. Daskow has been developing beauty products for Kline & Co. for 19 years and was a major force behind the company’s market research on at-home beauty devices.

Horst Rechelbacher, founder of Aveda Corp., died at his Wisconsin home after a three year battle with pancreatic cancer. An Austrian immigrant, he founded the company in Minneapolis in 1978, eventually selling it to Estée Lauder for $300 million. Rechelbacher was twice named one of the most influential environmentalists in the U.S. by Vanity Fair. He was 72.

Rechelbacher

Prof. Frank Clanet passed away on Jan. 22. In 1980, he invented the patented Sansair System, a method of aerosol can vacuum packaging with an aluminum bag, which is patented in the U.S. and Europe. He also developed, in collaboration with Hutchinson, the Pistobal—a flexible and elastic self sealing piston for use with aerosol piston cans. Clanet had a PhD in both Physical Sciences and Pharmaceutical Sciences, and at the time of his death, taught Environmental Chemistry at Tours University of Chemistry in France.

]]>http://www.spraytm.com/the-latest-in-personnel-changes.html/feed0LPNY releases show preview, seminar schedulehttp://www.spraytm.com/luxe-pack-new-york-releases-show-preview-seminar-schedule.html
http://www.spraytm.com/luxe-pack-new-york-releases-show-preview-seminar-schedule.html#commentsMon, 31 Mar 2014 14:49:43 +0000http://www.spraytm.com/?p=5895LUXE PACK NEW YORK 2014, the trade show for creative packaging, will be the largest event in its 12 year history, with nearly 200 exhibitors. This year, the event will feature several new elements including a new venue, new look, new section and new award. The event showcases the foremost innovative packaging in the world, as well as an extensive seminar schedule and a variety of special exhibits.

“We’re so pleased that LUXE PACK NEW YORK is the benchmark event for creative packaging in America, just like LUXE PACK MONACO is on a global scale,” said Nathalie Grosdidier, Executive Director, LUXE PACK. “This year, we are taking LUXE PACK NEW YORK to the next level with our new venue, the LUXE PACK in GREEN Award and LUXE PROMO. We’re very excited about the scope of the event this year and are sure it will excite visitors and exhibitors alike.”

Pier 92, located at 711 12th Avenue in Manhattan, is the new venue and allows the entire show to be located on one floor. It is a prime event venue in New York. An entirely new show look and booth design will also be unveiled in May.

LUXE PROMO Debuts

The new section, LUXE PROMO, is a dedicated show-within-a-show for creative promotional items for beauty and beverage brands. Offerings of customized and standard P-O-S merchandise, gifts with purchase, promotional gifts and other high-end premiums will include items such as: (beauty) make up bags, manicure sets, hair ornaments, samples, candles, soaps, massage gloves, jewelry, among others; and (beverage) glasses, ice buckets, wine bags, corkscrews and more.

First LUXE PACK in GREEN Award

The LUXE PACK IN GREEN AWARD, popular in Monaco, debuts in America this year. The award recognizes the exhibitor presenting the most innovative environmentally-friendly packaging solution. An esteemed jury of industry influencers has been selected to review the entries and select the winner based on sustainable criteria including materials, new and efficient processes and technologies and more.

The LUXE PACK NEW YORK Seminar Program is designed to provide visitors with dynamic insights and powerful inspiration. This year’s schedule features the latest in sustainability, creative collaboration, design, spirits packaging, skincare packaging trends, augmented reality technology, futuristic luxury trends and much more. Representatives of Brown-Forman, Elizabeth Arden, The Estée Lauder Companies, Material ConneXion, Pernod Ricard, L’Oreal, Mintel and Mirror Mirror Imagination Group are among the presenters.

Seminar Schedule

Wednesday, May 14

10:30am HOW SCENT CAN ACCELERATE A BRAND’S EQ

(EXPERIENTIAL QUOTIENT)

Sue Phillips, Founder & President of Scenterprises™ and The Scentsorium™

As more companies want to accelerate their EQ, scent is fast becoming the differentiator and consumers are helping brands to sniff their way to profits! As technology increases, scent is becoming a big part of the marketing mix and being used as a merchandising and branding element for corporations and in retail for environmental, digital and video applications. How does your brand smell?

Moderated and created by Jackie DeLise, Business & Brand Architect, Context

Don Droppo, Jr., President & CEO, Curtis Packaging

Brooke Baxter, Managing Member, Pavisa Glass

Doug Huffmyer, Vice President & Creative Director, Elizabeth Arden

Kevin Knight, President, K Group LTD

Global ideas, insights and experiences about what it takes to maintain luxury packaging ‘gold standards’ to cultivate brand relevance and marketplace excellence. What are the key process partner dynamics necessary when developing a luxury brand packaging? Learn: how to identify insights through sensorial connections and translate them into relevant, actionable consumer brand meaning; why a well-defined, visually

articulated strategy continues to elevate the brand beyond the competitive set; what’s new in printing of luxury packaging to enhance brand perceptions among consumers in the marketplace. Experience why design and innovation was, is, and will continue to be the key brand differentiator.

1pmLUXE IN LIGHT OF ENVIRONMENTAL RESPONSIBILITY: HOW PRESTIGE BRANDS ARE MEETING SOCIAL AND ENVIRONMENTAL CALLS FOR “GREENER” PACKAGING COMPLIANCE. (BEAUTY PACKAGING SUSTAINABILITY PANEL WITH JURY)

With online sales so important in cosmetics, marketers are more reliant on impactful packaging than ever. “Packaging the Promise” is essential to excite and invite clients into the brand. The promise of performance, efficacy, fantasy or aspiration must be implicit with the initial reaction to the packaging. Today, online consumers must depend on their visceral reaction and subliminal feelings to purchase online. Our panel of experts will address marketing, POP and design.

4pm LUXURY SKINCARE PACKAGING: STANDING OUT IN A CROWD

Dr. Benjamin Punchard, Global Packaging Insights Director, MINTEL

Mintel’s Global New Products Database recorded over 12,000 new skincare launches in 2013. Over 51% were in the Prestige, Luxe or Super Luxe positioning. Look at new launches and packaging trends from around the world including customization and the rise of sensory experiences to highlight how brands can stand out in this difficult space.

Thursday, May 15

10:00am NEW INNOVATIONS FROM EXHIBITORS: ENHANCING THE CONSUMER EXPERIENCE AND PRODUCT IMPACT

Exhibitor innovations help create an emotional impact with consumers through unique development and sensory cues, bringing the consumer-product-brand relationships to new heights. We will also showcase how collaborative efforts between packaging suppliers and brands can move from big-picture ideas to the small details that lead to evermore engaging creations.

Moderated and created by Linda Casey, Editor-in-Chief, Package Design magazine

Johnny Cárdenas, Design Director Brown-Forman

Kevin Shaw, Founder & Creative Director, Stranger & Stranger

Joan Nicosia, Adjunct Associate Professor, State University of New York

Designers and marketers are returning to pen and pencil to create liquor packaging that speaks to consumers’ quests for beauty in the things they drink, see and handle. An expert panel will look at how liquor brands are using illustration to attract attention on shelf, especially from newer drinkers, and deliver a more upscale, luxury experience to those consumers.

1pm LUXURY NUANCES / CUSTOMER CONNECTIVITY AND COMMENTARY

Created and moderated by Pamela D’Alessandro, Bellwyck Packaging Solutions

Leslie Harrington Ph.D, Executive Director, The Color Association of the US

What are the nuances in luxury packaging that speak to our customers and spark desire? How do these nuances lure us into deeper, personal brand experiences? How does this customer connectivity impact a brand culture? Diverse aspects and insights of luxury packaging and brand experience will be explored by this unique panel in an engaging commentary.

2:15pm THE POWER OF INTERACTION: WELCOME TO THE “NEW REALITY” AR (AUGMENTED REALITY) TECHNOLOGY

As technology advances, so does consumers’ expectations. Brands and retailers are starting to use AR technology, a hot topic among media and early adopters. Designers need to know there is a deeper resonance with how to use technology, while also thinking about overarching narrative that is both awe-inspiring and relevant to the brand ethos. Hear stories of successful strategies, insights and tactics, missed opportunities and how AR can enhance the next generation of marketing and advertising.

A powerful glimpse into a futuristic world where beauty, food, creative cocktails, home décor, sports, travel … all collide. A new fusion of luxury and retail trends you can see, taste, live, love, buy, desire and enjoy in this insightful futuristic trend presentation by this leading trend forecaster and brand innovator.

]]>http://www.spraytm.com/luxe-pack-new-york-releases-show-preview-seminar-schedule.html/feed0Food & Drug law book now available in 7th Editionhttp://www.spraytm.com/food-drug-law-book-now-available-in-7th-edition.html
http://www.spraytm.com/food-drug-law-book-now-available-in-7th-edition.html#commentsThu, 13 Mar 2014 17:12:19 +0000http://www.spraytm.com/?p=5838the new completely updated and expanded “reader friendly” 7th ed. of Food & Drug law book by Roseann B. Termini, Esq. was recently published in print and ebooks.

Quick Description: This “Go To” Resource” print edition contains 12 volumes (60 chapters in all) and is organized into separate subject specific volumes with a concise introduction to provide a roadmap for the reader.

In addition to the new edition print book, to reflect the current state of the profession and the academic discipline of food and drug law, I chose to also separate the treatise into 12 stand-alone ebooks, each available separately, and organized by subject area as Food and Drug law has become increasingly specialized. You will get a better idea of what I mean if you go to the fortipublications.com link to see both the print and the stand-alone Ebooks. Alternatively, you can find each ebook on Amazon . The new 7th ed. print edition is still available at www.fortipublications.com.

On Jan. 20-21, the National Conference of Weights & Measures (NCWM) held a meeting in Albuquerque, NM. During this meeting, the Laws & Regulations (L&R) committee held its Open Hearings, when any interested stakeholder could comment on current amendments. Comments were made on the Bag-on-Valve (BOV) labeling issue and whether BOV containers should label products using volume or weight to declare contents.

During an earlier January meeting held by the National Institute of Standards & Technology (NIST), industry believed there was a consensus to label BOV by weight, the same as traditional aerosols. However, two days before the meeting, two letters opposing the weight declaration were received. During the Open Hearings, however, all comments were in favor of declaring the contents of a BOV container by weight.

Later in the meeting, the L&R committee met in a closed meeting and voted to move the BOV debate to a voting issue at their June meeting. Thus, Weights & Measures will vote on this issue in June and the standard will be effective January 2015. At present, it appears that the L&R committee will vote to have the contents of BOV containers declared by weight. Still to be determined is the sell-through period. More to come after the June meeting.

SNAP Meeting

On Feb. 4, the U.S. Environmental Protection Agency (EPA) held a meeting to discuss changes to their Significant New Alternatives Policy (SNAP) Program. There are several changes proposed for refrigerants that will likely be put in place in 2014 with various effective dates. The EPA is proposing to make changes to Consumer Aerosols as well, possibly including the delisting of HFC-134a, HFC-227ea and HFC-125 for use in non-medical and non-technical aerosols. If the EPA delists these compounds, they can no longer be used in aerosols. The EPA believes the timing for this change will be proposed in the summer of 2014. No effective date was given. In addition, there currently is no official definition of non-technical aerosols.

The EPA is asking for comments on this issue sooner rather than later. Industry needs to review its uses of these chemicals and comment to the EPA.

CARB

The California Air Resources Board (CARB) still has not released its 15-day comment notice, which is needed to finalize its Board action of September 2013 on the Consumer Products and Aerosol Coating regulation. The amendments need to be finalized now that it is 2014. Industry needs the clarification that these amendments will provide. Currently, Industry is apprehensive about using the amendments before they become law. In past rulemakings, CARB Enforcement has not enforced against any changes made by the executive board at the hearing. Once the 15-day comment period is over, the Office of Administrative Law can finalize the amendments for use by the Industry.

SCAQMD 1168

South Coast Air Quality Management District (SCAQMD) is amending rule 1168 on Adhesives & Sealant products. SCAQMD is again trying to regulate consumer products. In its latest draft, SCAQMD has stated that its rule 1168 is applicable to all adhesives and sealants, which are consumer uses that are not currently regulated with a VOC limit in the CARB regulation. This is a horrible precedent. If readers recall, when SCAQMD went after Multi-purpose Solvent & Paint Thinners, I stated that this could spread to other categories. Well, here we go!

]]>http://www.spraytm.com/weights-measures-snap-carb-and-scaqmd.html/feed0What factors are necessary for corrosion to occur?http://www.spraytm.com/what-factors-are-necessary-for-corrosion-to-occur.html
http://www.spraytm.com/what-factors-are-necessary-for-corrosion-to-occur.html#commentsSat, 01 Mar 2014 05:01:15 +0000http://www.spraytm.com/?p=5766Hello, everyone. Corrosion is the degradation of materials from either a chemical or electrochemical reaction. Chemical corrosion is typical of polymer materials, such as coatings and laminate films. Electrochemical corrosion is typical of metals and involves removal of electrons from the metal with a corresponding change of chemical state for atoms at the corrosion site.

An often asked question is: what basic factors are necessary for spray package corrosion? There are three basic factors needed to initiate and propagate corrosion:

Environment

Materials

Surface

Environment

The environment is your formula, as well as occluded areas inside the various types of spray packages. Crimps between container components—e.g. tops and bottoms or valves and curls—form occluded areas between the components. The welds in laminated foil bags are also occluded areas.

The flow of your formula into occluded areas is restricted, which allows for the formation of microenvironments inside an occluded area, particularly when corrosion occurs in the occluded area. The liquid inside an occluded area often has a significantly different composition from that of your formula.

Formula (environment) corrosivity is determined by 1) the chemical composition of a formula, 2) the physical form of the formula, such as emulsion, aqueous or ethanol-water and 3) the stability of the formula. The same factors determine if a corrosive microenvironment will form inside an occluded area.

Emulsions are not thermodynamically stable and will break after a certain length of time or when the emulsion is exposed to high temperatures. A broken emulsion produces a water phase that might be corrosive.

Formula ingredients might also be unstable and decompose over time or at high temperatures. Decomposition of formula ingredients could transform a benign formula into a voracious package-eater.

Materials

There are numerous different types of materials used in spray packaging:

Steel coated with tin metal (tinplate or ETP)

Tinplate coated with a variety of polymer coatings

Steel coated with a very thin layer of chromium (tin-free steel)

Tin-free steel coated with polymer coatings

Tin-free steel with a polymer film (the film is often referred to as a laminate)

Aluminum and aluminum foil

Aluminum coated with a variety of polymer coatings

Aluminum foil coated with a variety of laminate polymer films (often referred to as laminated foil)

Stainless steel (typically used only for aerosol valve spring and check balls)

The degree of corrosivity for a given type of formula toward a given type of material is also determined by 1) the chemical composition of a formula, 2) the physical form of the formula, such as emulsion, aqueous or ethanol-water, 3) the stability of the formula and 4) the type of material. The same factors determine if a corrosive microenvironment will form in the occluded area for a given type of package material.

Surface

Corrosion by the environment occurs on the surface of the package material. Surface metal atoms are different from bulk metal atoms, which are surrounded by other metal atoms. Bulk metal atoms share valence electrons, resulting in saturated valence shells.

In contrast, the surface atoms are not completely surrounded by other metal atoms. Consequently, there are not enough shared electrons to completely saturate surface atom valence shells, making surface atoms thermodynamically unstable.

Electrochemically active ions and molecules in your formula remove valence electrons from the surface metal atoms. Removing valence electrons further destabilizes the surface atoms, causing atoms to be ejected from the surface as metal ions. The new metal ions are thermodynamically stable.

Electrochemically active hydrogen ions are present whenever there is water in your formula. More hydrogen ions are present in low pH formulas (e.g., pH of four) than in high pH formulas (e.g., pH of 10). Consequently, low pH formulas are potentially more corrosive—but not necessarily—than high pH formulas.

Water molecules are electrochemically active. It takes approximately 90 water molecules to initiate corrosion. However, it takes additional water molecules to sustain corrosion because metal corrosion consumes water.

Polymer (coatings and laminates) corrosion involves the movement of ions, water and select formula ingredients into and through the polymer. Water tends to open up the polymer as it is absorbed and diffuse between the polymer molecules. Water also breaks polymer-metal bonds causing polymer delamination, such as blistering. Metal corrosion under a polymer could also cause polymer delamination and pitting corrosion.

The metal-polymer bonding is different for each type of metal. For example, epoxy coatings bond differently to tinplated steel, tin-free steel and aluminum. Thus, the surface with an epoxy coating is different for each type of metal and their corrosion behaviors are also different.

Conversely, the metal-polymer bonding is different for each type of polymer. For example, polyacrylamide (PAM)-coated aluminum has a different surface than a corresponding epoxy-coated aluminum, and the corrosion by a given formula is often significantly different for the two different coatings.

Want to learn more about spray package corrosion? We would be happy to teach our Elements of Spray Package (Aerosol Container) Corrosion short course at your R&D facility. Please contact rustdr@pairodocspro.com or visit www.pairodocspro.com. Please send your questions/comments/suggestions to rustdr@pairodocspro.com. Back issues of Corrosion Corner are available on CD from ST&M. Thanks for your interest and I’ll see you in April.

]]>http://www.spraytm.com/what-factors-are-necessary-for-corrosion-to-occur.html/feed0GHS Moves Forwardhttp://www.spraytm.com/ghs-moves-forward.html
http://www.spraytm.com/ghs-moves-forward.html#commentsSat, 01 Mar 2014 05:00:45 +0000http://www.spraytm.com/?p=5771Things are heating up fast with only 18 months to go until companies will need their Safety Data Sheets (SDSs—formerly MSDSs) and workplace chemical labels compliant with the U.S.’s Globally Harmonized System of Classification & Labeling of Chemicals (GHS)-based Hazcom 2012 regulations. Here at Nexreg, we have noticed an uptick in panicked calls, with companies learning about the significant burdens this regulation will place on them. We recommend that all of our friends in the chemical industry develop a plan of action immediately, detailing how they will become compliant with the new regulation, as it will be difficult to find consultants to author documents or give SDS authoring software training as the deadline approaches.

If the upcoming U.S. deadline has not causing enough problems, there have been significant developments in many major markets when it comes to GHS-based regulations. GHS is truly becoming global, although it is far from harmonized. Here is what we have been keeping an eye on the last few months:

United States

In the last few months, The U.S. Occupational Safety & Health Administration(OSHA) has released several important documents to assist companies becoming compliant with the GHS based Hazcom 2012 regulation. This guidance is incredibly appreciated, though we would have preferred that this information arrived sooner. The most important documents are the following:

The OSHA Quick Card that compares Hazcom 2012 labels with the existing National Fire Protection Association (NFPA) 704 labels is incredibly useful and should be included in all employee training materials. It can be downloaded in PDF form at http://1.usa.gov/MmXoJC.

Another important piece to include in training materials is the new OSHA Hazard Communication wallet card, which contains a QR code allowing workers to get more information on Hazcom 2012 using cellphones. The cards can be obtained at http://1.usa.gov/1frThGy.

Less applicable to most aerosol firms is the recent letter of interpretation of the classification of combustible dusts, available at: http://1.usa.gov/1f9MrUK.

We’re still waiting for a letter of interpretation or additional guidance on the classification for “Hazardous not Otherwise Classified.” Additionally, the line between what is considered a consumer product and what is considered a workplace product as not as clear as it is in such jurisdictions as Canada, so we are hoping OSHA will clarify this in the coming months, as well.

Canada

Speaking of Canada, many of us were hoping that the final version of the Hazardous Products Regulations (HPR) would be released by the end of 2013, but it was not meant to be. The draft HPR, released in mid-2013, was mostly harmonized with the U.S. Hazcom 2012 implementation of GHS, though there were some significant differences. At a minimum, I believe Health Canada will allow at least a two year transition period for compliance, so do not expect the final compliance date for SDSs and labels to be harmonized with the June 1, 2015 date for U.S. compliance.

In unrelated news, the Conservative government has announced a “one-for-one” bill that will require the government to repeal a regulation for every new regulation that is added. The draft bill specifically excludes regulations dealing with health and safety, so it is not likely to affect regulations of interest to the aerosol community. However, it is possible this exemption may get removed

China

China has published its GHS standard, known as “Guidance on the Compilation of Safety Data Sheets for Chemical Products.” I have not seen an English translation of this standard (GB/T 17519-2013), but I am hopeful one will emerge in the next few months. Like the EU, this new standard is based on the 4th revised edition of the U.N.’s purple book. Unlike the European Union, this standard is only recommended, not required. However, as a best practice, we are advising our clients to treat this standard as mandatory.

Turkey

Turkey has issued its final GHS rule, the Regulation on Classification, Labeling & Packaging of Substance and Mixtures. It is similar in style and scope to the EU’s Classification, Labeling & Packaging (CLP) regulation. I have been unable to locate an English version of regulation 28848, but a Turkish language version exists at http://bit.ly/MnetTU. Manufacturers and importers will be required to notify the Turkish government of both pure substances and substances within mixtures to the Turkish government. This notification period spans from June 1, 2014 to June 1, 2015. For new substances placed on the market after June 1, companies have one month from date of manufacture or import to notify the government. If your company has any products that are imported into Turkey, you will want to learn about these new requirements immediately.

As with CLP and other GHS-based pieces of regulation, there are label and safety data sheet requirements. Firms have until June 1, 2015 to update labels and SDSs for pure substances and June 1, 2016 for mixtures. We are still becoming familiar with this new regulation, but if it is as harmonized with the EU regulations as it appears, we do not believe the label and SDS provisions should provide large regulatory burdens on importers (since most will already have EU compliant documents). The notification requirements, on the other hand, could cause problems.

What to expect next

By spring 2014, we should have a final Canadian rule on GHS, a final version of the 6th ATP to the EU’s CLP regulation and hopefully some additional guidance from OSHA on some of the thornier problems created by Hazcom 2012. As always, we will be keeping a close eye on developments.

Dan O’Hare was made the LINDALGroup’s new Eastern Regional Sales Manager for North America. With more than 20 years of sales experience, his duties will be expanding the company’s customer base and maintaining key accounts in the eastern U.S.

Lauder

The Estée Lauder Companies, Inc. announced that Jane Lauder has been named Global Brand President, Clinique. Lauder was previously Senior VP/Global General Manager, Origins, Ojon and Darphin. Stephane de la Faverie will succeed her in that position.

Estée Lauderhas also promoted Chris Good to the position of President, U.K. and Ireland, and Sandra Main the position of Global Brand President, La Mer.

Fitzgerald

CAPCO announced that Sean Fitzgerald has been named Chairman of the Board of Directors. Currently Director of Sales in the aerosol division of Cobra Plastics, Fitzgerald’s sales career in the aerosol industry has spanned 24 years.

The American Cleaning Institute has honored Robert Hamilton with its annual Elva Walker Spillane Distinguished Service Award. Hamilton has spent the last 37 years developing detergents, cleaners, and specialty chemical formulations for AmwayCorp. Since 2000, he has served as the company’s Regulatory Policy Director.

Coty, Inc. appointed Catia Cesari to the position of Senior VP Business Development, Mergers & Acquisitions.

Helen of Troy named Julien Minninberg President and CEO of the company’s healthcare and home environments division. Minninberg previously worked at Proctor & Gamble.He will succeed company founder Gerald Rubin. Timothy Meeker will succeed Rubin as Chairman of the Board.

Denise Costrini and Doug Krysiak joined Croda, Inc. as Marketing Manager and Sales Manager, respectively. Costrini brings marketing and research experience from Dow Chemical and Univar. Krysiak previously worked at Dow Corning and TRI-K Industries.

Additionally, Chris Dederen, Research and Technology Specialist for Croda, was honored with the Allan R. Black award for best presentation at last year’s Society of Cosmetic Chemists annual conference. Dederen’s winning presentation, “Sensory Mapping Methodology Detects the Substantial Perceptible Effects of Emulsifiers in Emulsions,” is part of a body of research that led to Croda’s development of the Sensification program.

Chartier

Drom Fragrances has named Beatrix Chartier as its Fine Fragrance Evaluation Director International. Previously, she served as Fine Fragrance Director for Quest and later for Givaudan.

Henein

TRI-K Industries, Inc. appointed Emile Henein to the position of Business Manager–Actives. He was previously Industry Manager at BASF and most recently Global Business Manager at Stepan.

Lim

CY Lim was named Director of Global Glass—Asia for TricorBraun. In this capacity, Lim will oversee all glass product sourced from Asia, as well as investigate potential new suppliers.

]]>http://www.spraytm.com/lindal-group-names-new-regional-sales-manager.html/feed0PCPC Annual Meeting off to a good starthttp://www.spraytm.com/pcpc-annual-meeting-off-to-a-good-start.html
http://www.spraytm.com/pcpc-annual-meeting-off-to-a-good-start.html#commentsFri, 28 Feb 2014 14:38:21 +0000http://www.spraytm.com/?p=5801Nearly 500 industry leaders from around the world have gathered at the Personal Care Products Council’s 120th Annual Meeting to discuss global business opportunities, emerging consumer trends and elect new officers, the Council announced today.

Council President and CEO Lezlee Westine said the agenda mirrored the industry’s constant efforts to improve and innovate. “Each year we try to top the previous year’s conference and we are thrilled once again to have a variety of panels and thought provoking keynote speakers to inspire our members,” said Westine.

“One of the most exciting things to look forward to in 2014 is Look Good Feel Better’s 25th Anniversary celebration,” said Scott Beattie, President and CEO of Elizabeth Arden and Council Board Chairman. He noted how effective the Council’s Foundation has been in providing nearly 1.5 million women worldwide with unique workshops that improve cancer patients’ self-esteem and quality of life.

“We are extremely proud of the industry’s commitment to this program and are grateful for its generous support,” said Beattie during his welcoming address.

Event Highlights:

Keynote speaker Tony Hsieh, author of the #1 New York Times Bestseller, “Delivering Happiness” and Zappos CEO, kicked off the conference during the first all-attendee dinner.

Jonah Berger, James G. Campbell Associate Professor of Marketing at the Wharton School at the University of Pennsylvania shared topline details from his research on how to craft contagious content.

Mary G. Berner, M.P.A., President and CEO of The Association of Magazine Media, elaborated on how to maximize marketing allocations to compete with the constant clutter consumers are showered with. Following her discussion was a panel on how the Millennial Generation is shaping the present and owning the future.

Upcoming Events:

One of the General Sessions will feature two panel discussions. The first will be with Council senior staff about the continuing and emerging issues affecting the industry. The second will be moderated by Lisa Powers, EVP of Public Affairs and Communications, on how to gain and maintain stakeholders’ trust. The discussion will feature Michael Maslansky, CEO, Maslanksy + Partners; Scott Siff, Vice Chairman Penn Schoen Berland and CEO BAV Consulting and Jennifer Cohan, Global Chair of Consumer Marketing, Edelman.

Rana Foroohar, Columnist, TIME; Global Economic Analyst, CNN will address patterns in the world economy that business leaders and investors should be focused on. Her presentation will be followed by a panel discussion with executives from Mary Kay and Lubrizol regarding their individual perspectives on the international opportunities and challenges facing the industry.

Beattie, who was re-elected to a second term as Council Chairman, summarized the Council’s 2013 accomplishments, including the industry’s work with the FDA to modernize the nation’s regulatory structure.

He also noted successful efforts to promote international collaboration and said, “progress is being made, and we plan to add other long-term areas of cooperation to the agenda and expand it to other countries in due course.”

]]>http://www.spraytm.com/pcpc-annual-meeting-off-to-a-good-start.html/feed0Chinese Authorities Take Action against Honeywell Counterfeitershttp://www.spraytm.com/chinese-authorities-take-action-against-honeywell-counterfeiters.html
http://www.spraytm.com/chinese-authorities-take-action-against-honeywell-counterfeiters.html#commentsFri, 21 Feb 2014 17:40:19 +0000http://www.spraytm.com/?p=5724Honeywell announced that Chinese authorities have penalized two Chinese companies who fraudulently manufactured and sold counterfeit refrigerants under the Honeywell Genetron brand name for the Chinese market.

The companies, Changzhi Co. and Yingpeng Co., were ordered by a Chinese court in Shanghai to pay $52,000 in damages and make a public apology to Honeywell. Changzhi Co. was previously convicted under the crime of trademark counterfeiting and its principal was sentenced to jail for 3 years with a probation of 3 years.

“Honeywell continues to work closely with local law enforcement and other authorities to actively pursue and help prosecute counterfeiters of our Genetron refrigerants,” said Paul Sanders, managing director for Honeywell Fluorine Products in Europe, Middle East, Africa and India. “Counterfeit refrigerants can be flammable and can pose a serious danger to contractors, consumers, and refrigeration equipment. Users should demand product that originates from reputable producers like Honeywell.”

The seizure was part of a joint effort between the company and local law enforcement in Shanghai. According to local authorities, the counterfeit refrigerant was marked as Honeywell’s Genetron 410A and 407C.

All Genetron refrigerants are subject to extensive quality and safety testing before they are sold. The safety and quality of Genetron refrigerants can only be guaranteed when buying the refrigerant from Honeywell-authorized suppliers.

Honeywell Performance Materials and Technologies has actively pursued counterfeits for more than 10 years with successful seizures in more than 20 countries covering six continents. During the last two years alone, Honeywell, working with local governments, have seized more than 200,000 counterfeit products. Since 2007, Honeywell has conducted 13 raids in China and seized more than 18,000 counterfeit products there.

Honeywell continues its efforts to build awareness among end customers on risks of using counterfeit products. These include creating posters that explain how dangerous it can be to use non-genuine products as well as training for contractors on the proper use of refrigerants.

]]>http://www.spraytm.com/chinese-authorities-take-action-against-honeywell-counterfeiters.html/feed0MAA launches new websitehttp://www.spraytm.com/maa-launches-new-website-2.html
http://www.spraytm.com/maa-launches-new-website-2.html#commentsTue, 18 Feb 2014 21:25:52 +0000http://www.spraytm.com/?p=5714The Midwest Aerosol Association’s (MAA) new website is up and running. Check it out at http://oktospray.org. The MAA requests that visitors clear out browsers so as to not pull up the old address.

Also, The MAA requests that visitors be sure to register for the MAA Spring Meeting while there.

]]>http://www.spraytm.com/maa-launches-new-website-2.html/feed0Aveda Founder dies of pancreatic cancerhttp://www.spraytm.com/aveda-founder-dies-of-pancreatic-cancer.html
http://www.spraytm.com/aveda-founder-dies-of-pancreatic-cancer.html#commentsTue, 18 Feb 2014 20:21:50 +0000http://www.spraytm.com/?p=5704Horst Rechelbacher, founder of Aveda Corp., died Feb. 15 at his home in Osceola, WI. He was 72. The cause was pancreatic cancer.

Born in Austria, Rechelbacher founded Aveda Corp., which grew from a small salon hair care brand to a leading player in natural and eco-friendly personal care. Rechelbacher sold Aveda to The Estée Lauder Companies in 1997 in a deal that was valued at around $300 million.

However, Nestle said on Tuesday it remained committed to the maker of Garnier shampoo and Lancome creams for the “long haul”, dampening speculation it might sell its remaining 23 percent stake anytime soon.

“This transaction is a bit of a let down,” Liberum Capital analysts said in a note, referring to media reports that L’Oreal might buy a larger proportion or even all of Nestle’s stake.

At 9.25 a.m. ET L’Oreal shares, which had leapt on Monday on speculation of a larger stake purchase, were down 3.6 percent at 124.4 euros. Shares in Nestle, home to Gerber babyfood and Kit Kat chocolate bars, were down 1 percent at 66.9 Swiss francs.

The Swiss firm has been a major shareholder in L’Oreal since 1974, when L’Oreal heiress Liliane Bettencourt, now the world’s richest woman, sold around half her stake to Nestle for fear L’Oreal would be nationalized if Socialists came to power.

Under their pact, Nestle and Bettencourt promised not to sell their stakes without first offering them to the other.

With that agreement due to expire on April 29, 2014, speculation had been mounting the two firms would strike a deal before Nestle became free to sell its stake elsewhere.

L’Oreal said it would cancel all the shares it buys from Nestle, boosting its earnings per share by more than 5 percent.

But it will have to wait to buy more shares – if it is offered the opportunity – as French rules mean it cannot cancel more than 10 percent of its shares over an 18 month period.

Nestle said it would use cash proceeds from the deal to buy back its shares, without disclosing details.

L’Oreal will pay for the deal with 3.4 billion euros in cash and by selling to Nestle its 50 percent stake in their Galderma dermatology venture for 3.1 billion euros, including about 500 million of debt, which Nestle will pay for in L’Oreal shares.

One of the highlights of the deal for Nestle was the Swiss group’s commitment to grow its dermatology business as part of its drive to focus on health, wellness and nutrition.

Nestle will create a unit called Nestle Skin Health to include Galderma, which makes a rival to Allergan’s (AGN.N) Botox called Azzalure, and an existing infant skin care unit.

This division “shows which direction Nestle plans to take,” said Laurent Dobler, manager of the Renaissance Europe fund with more than 1 billion euros under management. “The dermatology market is fragmented but promising.”

Nestle is paying a multiple of 26 times Galderma’s 2013 operating profit, which some analysts said was not cheap considering the venture’s sales growth slowed to 3.9 percent in 2013 from 5.9 percent in 2012.

While some analysts were disappointed Nestle did not sell a larger stake in L’Oreal to fund a bigger buyback, Bernstein’s Andrew Wood said ongoing relations between the two firms kept open options for future nutrition-cosmetics ventures.

“We note that the Inneov (nutri-cosmetics) joint venture between Nestle and L’Oreal was not included in today’s transaction, and remains a crossover area,” he said.

L’Oreal said it could fund the deal without selling its 9 percent stake in drugmaker Sanofi (SASY.PA), worth $12 billion, dampening speculation Sanofi might get a chance to buy back the stake and boost its own earnings per share. <ID:L5N0LG1ZM>

The deal will cut Nestle’s holding in L’Oreal to 23.29 percent from 29.4 percent, while the Bettencourt Meyers family’s stake in L’Oreal will rise from 30.6 percent to 33.31 percent. The deal is expected to close in the first half of this year.

Explaining the deal, L’Oreal’s Agon said: “Nestle’s stake reduction had to allow it to remain a strategic shareholder … while making sure that the Bettencourt family stayed below the 33.33 percent level.” Beyond that level, the family would have to make an offer for the rest of L’Oreal’s share capital.

Some analysts said it was possible the Bettencourts could obtain a waiver from regulators from having to make an offer for the rest of L’Oreal if Nestle decided to sell more of its stake to the French firm and the shares were canceled – which would raise the Bettencourts’ stake beyond 33.33 percent.

Marco Sormani at Varenne Capital Partners, which has 200 million euros under management including shares in L’Oreal, said buying back its shares made sense for the cosmetics group. “Considering the low-interest rate environment, you make much better use of your cash buying back shares and cancelling them than letting the cash sit on your balance sheet,” he said.

L’Oreal had net cash of 2.2 billion euros at the end of December and estimated it would have net debt of 700 million euros after the transaction.

Nestle was advised by Rothschild and L’Oreal by BNP Paribas and Lazard.

]]>http://www.spraytm.com/nestle-cuts-stake-in-loreal-but-staying-for-long-haul.html/feed0CSPA Seeks Comments on New Cleaning Product Guidance Documentshttp://www.spraytm.com/cspa-seeks-comments-on-new-cleaning-product-guidance-documents.html
http://www.spraytm.com/cspa-seeks-comments-on-new-cleaning-product-guidance-documents.html#commentsFri, 07 Feb 2014 14:48:24 +0000http://www.spraytm.com/?p=5599The Consumer Specialty Products Association (CSPA) is currently seeking public comments on the following test method guideline: “Microbiological Examination of Household and Institutional Products: Microbial Enumeration Test Guidelines.” Specifically, this guideline was created for enumeration tests that will allow quantitative enumeration of mesophilic bacteria and fungi. These tests are designed to establish compliance to raw material, manufacturing intermediate and finished product microbiological specifications. In addition, CSPA is also seeking comment on the following general guidance documents that were recently approved by the Division’s Microbiology subcommittee:

i. Microbiological Quality of Finished Products

ii. Microbiological Quality of Raw Materials

Please note that these guidelines do not apply to foods, drugs or cosmetics. They also do not apply to those organisms within products whose user benefit is established via viable microbial populations (e.g. biological drain/trap cleaners). Reviewers will have 30 days from this release to submit their comments or feedback to CSPA.

For questions or to request a copy of the guidance documents for review, please contact CSPA’s Cleaning Products Division Staff Executive Tim Brown at tbrown@cspa.org. The finalized guidelines will be available for purchase individually via the CSPA website. In addition, once approved, the guidance documents will be included in the CSPA’s Cleaning Products Compendium.

CSPA’s test methods and guidelines are used by those engaged in the formulation, manufacture or marketing of cleaning products. The availability of the test methods and guidelines are the result of a collaborative and consensus research and evaluation process with input from CSPA member companies and the public.

About CSPA

The Consumer Specialty Products Association (CSPA) is the premier trade association representing the interests of companies manufacturing, formulating, distributing and selling more than $100 billion annually in the U.S. of familiar consumer products that help household and institutional customers create cleaner and healthier environments. CSPA member companies employ hundreds of thousands of people globally. Products CSPA represents include disinfectants that kill germs in homes, hospitals and restaurants; candles, and fragrances and air fresheners that eliminate odors; pest management products for home, garden and pets; cleaning products and polishes for use throughout the home and institutions; products used to protect and improve the performance and appearance of automobiles; aerosol products and a host of other products used every day. Through its product stewardship program, Product Care®, and scientific and business-to-business endeavors, CSPA provides its members a platform to effectively address issues regarding the health, safety and sustainability of their products. For more information, please visit www.cspa.org

“In the second phase of this project, we identify publicly available hazard data for each chemical ingredient used in our members’ formulated consumer cleaning products in our Hazard Data Portal,” said Dr. Paul DeLeo, ACI Senior Director of Environmental Safety.

“This initiative represents the cleaning product industry’s continued commitment to transparency and further showcases the responsible management of cleaning products and their ingredients.”

ACI developed the Cleaning Product Ingredient Safety Initiative (CPISI) as one of its many efforts to shed light on the safe use of ingredients in their members’ products, including the underlying scientific data and the methods in which these data are applied in making decisions.

“One of the biggest falsehoods in public discussions about chemicals in commerce is that there is little-to-no information available about the ingredients in consumer products,” said Dr. DeLeo. “All of the data gathered for the ingredients in our Inventory is publicly available. We’ve created a portal to make it accessible in one place.”

“In this first iteration of our Hazard Data Portal, we found that sufficient information was available for decision-making and risk assessment for 80 percent of ingredients in the cleaning products of ACI members,” said DeLeo.

“Substances found to lack primary hazard data during this effort are often considered safe under other assessments or regulations; this includes food materials and food additives.

“Simply put, the development of the Hazard Data Portal has provided us a robust database for screening-level risk assessment of cleaning product ingredients.”

The data available on the ACI website will be most useful to regulators, researchers, and cleaning product industry formulators and suppliers looking for detailed information on ingredients used in consumer cleaning products.

]]>http://www.spraytm.com/cleaning-product-ingredient-safety-data-now-available-on-aci-website.html/feed0MAA to host Continuing Education Seminarhttp://www.spraytm.com/maa-to-host-continuing-education-seminar.html
http://www.spraytm.com/maa-to-host-continuing-education-seminar.html#commentsTue, 04 Feb 2014 20:15:55 +0000http://www.spraytm.com/?p=5592The Midwest Aerosol Association (MAA ) will be hosting a one day Continuing Education Seminar with various topics covering the various aspects of the aerosol package.

This webinar will provide an overview of regulations and trends that impact cosmetics manufacturing and marketing in 2014. Don’t miss this opportunity to speak with industry experts and ask the questions.

Former Aerosol Association of Australia President Lindsay Showyin has had his contribution to the aerosol industry recognised in the 2014 Australia Day Honours, receiving an Order of Australia Medal (OAM) for his services to the manufacturing industry and to professional associations.

Before stepping down late last year, Mr Showyin had served as the Association’s President for nearly 30 years, overseeing a number of important Association and industry initiatives, including the shift from CFC propellants, the acceptance of post-consumer aerosols in kerbside recycling, the Association’s Award-winning series of television, print and radio commercials and in recent years its pro-active engagement with aerosol associations throughout the Asian region.

He joined the Association’s Executive Committee in February 1976, becoming President in 1984.

1976 also saw him joining the newly established PK/13 Technical Committee of Standards Australia and as its Chair he played a pivotal role in the development of AS2278, the Australian Standard which prescribes safety standards for locally sold aerosols.

Speaking on the Award, Mr Showyin noted that highlights of his time at the helm of the Association included the development of the “It’s OK to Spray” campaign by the Association in conjunction with its New Zealand counterpart in the mid-1980’s, the launch of the Aerosol Industry Awards in 1994, and the establishment of the Asian Aerosol Federation in late 2011.

Mr Showyin remains on the Association’s Executive and is President of the Asian Aerosol Federation.

The next meeting of the Federation will be held in Sydney in early April, as part of the ‘aerosolsydney2014’ series of events – for more information see www.aerosolsydney2014.com.

Priorities for the American Cleaning Institute (ACI; Washington) in 2014 focus on advancing chemical management reform and continuing efforts to strengthen technical, outreach, and education programs, says Ernie Rosenberg, president and CEO of ACI. The organization will hold its annual meeting and industry convention in Orlando, FL, 27 January–1 February.

One of ACI’s, as well as other industry groups’, priorities is ensuring that efforts to modernize chemical management move forward following last year’s introduction of a bipartisan bill to reform the Toxic Substances Control Act (TSCA). Introduced in May 2013 by the late Senator Frank Lautenberg (D., NJ) and Senator David Vitter (R., LA), S. 1009—The Chemical Safety Improvement Act (CSIA) of 2013—has been hailed by industry, lawmakers, and nongovernmental organizations as a compromise that addresses key TSCA inadequacies and can serve as an effective template for meaningful chemicals management reform.

“We are confident that the Vitter-Lautenberg Senate bill will proceed,” Rosenberg says. “We have a bill with 25 bipartisan cosponsors, which is, by itself, an achievement in this polarized environment. And, we expect additional Senate support for the bill.” Rosenberg expects the House to introduce legislation soon that will be largely consistent with what Vitter and Lautenberg propose. “We don’t know if it will be as broad, but we do see both chambers working together on the issue, which is also encouraging and notable,” Rosenberg says.

One of the key areas of debate over CSIA remains state preemption authority. “I think one of the critical issues will be maintaining business community support when a compromise does come out,” Rosenberg says. “We see room for compromise. We can’t discuss the specifics yet…. We’ll see what we get.”

A strong, credible federal management program will be in the interest of all parties and should ultimately reduce the need for state and local involvement, he adds. “With a credible program, if EPA finds that a chemical does not merit control, we don’t expect states to go after products,” Rosenberg says. “Also, we think states will defer to EPA on products that may need control, assuming EPA is given the resources and authority to move expeditiously.”

State chemical management efforts also remain a priority for advocacy efforts. Rosenberg expects ACI will be active as California advances regulation its green chemistry programs. “We are well positioned to help because of our science focus,” Rosenberg says. “We expect to support the effort.”

EPA may also expand its safer ingredients list under its Design for Environment (DfE) program. EPA added 130 chemicals in June 2013. For the first time, 119 fragrance chemicals for commercial and consumer cleaning products were added to the list. “We hopefully will see additional products added to the list as environmentally preferable,” Rosenberg says. “We are encouraged by movement there.”

ACI is also keeping a close eye on a proposed rule, issued by FDA in December 2013, that would require manufacturers of antibacterial hand soaps and body washes to demonstrate that the products are safe for long-term, daily use and are more effective than soap and water in preventing illness and the spread of certain infections. “We think data demonstrate efficacy and can debunk concerns about resistance,” Rosenberg says. “There is not a problem with antimicrobials used in hand washing,” he adds.

Technical, outreach programs expand

The group is strengthening efforts around disclosing ingredient research and data. “In the coming year, we will develop a Web portal that will have detail on data sets we use,” Rosenberg says. “It is all part of industry’s commitment to transparency. We recognize the demand for the data responsibility to address concerns of consumers.”

ACI will continue to make research widely available. “We don’t keep the science a secret. We have led efforts to get agreement across formulated products that we won’t try to edit, alter, or withhold scientific studies,” Rosenberg says. “There is a need to make sure they are conducted according to protocols that are scientifically valid and respected. And, if there is information that is adverse, we are lucky to represent an industry that will take that seriously and address it instead of trying to quash findings.”

Consumer outreach and education efforts will focus on laundry safety, including the risk around consumption of single-dose packets or pods by children. “It is a major area of focus,” Rosenberg says. “We want parents to be aware that products need to be kept out of the reach, and preferably out of view, of children and pets.”

Sustainability communication is also important. ACI expects to release a new sustainability report in early 2014 and will continue to advance its metrics program. “Sustainability initiatives give us ability to showcase what cleaning products supply chain is doing to enhance sustainability of products,” Rosenberg says. “It goes beyond safety. We are trying to demonstrate how we can increase effectiveness while lowering volumes, reducing water use, and allowing lower temperatures.” Sustainability metrics for an organization that focuses on ingredients and products—not facilities—is a “knotty problem. You can’t do it in a dumb way,” Rosenberg says. Companies are adept at measuring the reducing environmental impacts at plants and plant sites. “For measuring product efficacy, however, there is not a single set of metrics you can use,” he adds. The group is also moving forward on the development and creation of a sustainability charter.

Rosenberg says ACI enters its annual meeting after a strong 2013. “Membership is up, and our influence, particularly in the area of TSCA reform, has never been greater and is unmatched by any other downstream association,” Rosenberg says.

]]>http://www.spraytm.com/chemical-management-reform-outreach-acis-top-agenda.html/feed0NIST meeting determines BOVs to declare weight, not volumehttp://www.spraytm.com/nist-meeting-determines-bovs-to-declare-weight-not-volume.html
http://www.spraytm.com/nist-meeting-determines-bovs-to-declare-weight-not-volume.html#commentsFri, 17 Jan 2014 16:55:29 +0000http://www.spraytm.com/?p=5554On January 6, the National Institute of Standards & Technology (NIST) hosted a meeting in Gaithersburg, MD to discuss whether products utilizing bag-on-valve (BOV) technology should declare quantity on cans by weight or volume, as finally determined by the National Conference of Weights & Measures. The upshot of the meeting? BOVs shall declare their volume in weight, the same as “traditional” aerosols (although BOV containers labeled as volume will probably have a sell-through period of three years).

Read more about this in the February issue of SPRAY…

]]>http://www.spraytm.com/nist-meeting-determines-bovs-to-declare-weight-not-volume.html/feed0Lindal Group Appoints New Eastern Regional Sales Manager for North Americahttp://www.spraytm.com/lindal-group-appoints-new-eastern-regional-sales-manager-for-north-america.html
http://www.spraytm.com/lindal-group-appoints-new-eastern-regional-sales-manager-for-north-america.html#commentsFri, 17 Jan 2014 16:46:03 +0000http://www.spraytm.com/?p=5551The LINDAL Group—manufacturer of valves, actuators and spray caps for aerosol products— announced the appointment of Dan O’Hare to the position of Eastern Regional Sales Manager for North America. He will report to Alex Piagnarelli, Sales Director, North America and is charged with growing the company’s business and customer base and maintaining relationships with key accounts based in the eastern United States.

According to Phil Lever, Group Sales Director, Lindal Group, O’Hare has more than 20 years of sales experience, specializing in packaging and related products to the healthcare, medical and consumer product industries. Most recently, O’Hare held senior account manager positions with companies such as Kampack Inc., PacVantage and IVEX Packaging Corp.

“Dan’s appointment is important for us, as it forms a key part of our North American sales team enhancement,” Lever said. “Growth from multinational customers based on the East Coast will increase and Dan has the professional skills needed to help us meet the pent-up demand for innovative aerosol solutions.”

O’Hare resides in Metuchen, New Jersey, close to many of the company’s major East Coast accounts, including Unilever, Colgate, Church & Dwight, American Spraytech and L’Oreal.

]]>http://www.spraytm.com/lindal-group-appoints-new-eastern-regional-sales-manager-for-north-america.html/feed0Midwest Aerosol Association reminds members to renewhttp://www.spraytm.com/midwest-aerosol-association-reminds-members-to-renew.html
http://www.spraytm.com/midwest-aerosol-association-reminds-members-to-renew.html#commentsFri, 10 Jan 2014 15:18:20 +0000http://www.spraytm.com/?p=5542For those past MAA Members who have not already signed up for 2014, please remember to send in your 2014 Midwest Aerosol Association membership. For those MAA Members who have already signed up, Thank You!

This year you can either pay by check made out to MAA or even easier, go to the MAA website at www.oktospray.com and pay via PayPal on the main page. When pay by PayPal, you will receive an instant e-mail notification with your receipt of payment to the MAA. Whether you are paying by check or by PayPal, please fill-in the attached membership application and send the completed form to Michael Byrnes. Michael’s contact information can be found on the bottom of the application form. Please be aware that the cost of membership has not changed for 2014 but there will be an increase in the membership price after February 28th.

For Corporate Members, please be aware that you may include as many individuals as you would like. Please make sure you include these individual’s e-mail addresses so we can update our 2014 membership list. We will be using this list to send out notices about the different events throughout the year.

]]>http://www.spraytm.com/midwest-aerosol-association-reminds-members-to-renew.html/feed0PCPC promotes Powershttp://www.spraytm.com/pcpc-promotes-powers.html
http://www.spraytm.com/pcpc-promotes-powers.html#commentsTue, 07 Jan 2014 17:31:56 +0000http://www.spraytm.com/?p=5521The Personal Care Products Council (PCPC) announced that it has promoted Lisa Powers to Executive Vice President for Public Affairs and Communications, the organization’s top communications position.

Powers

“For the past eight years, Lisa has been a tireless advocate for our member companies, their commitment to safety, quality and innovation, and the consumers who trust and use our products every day,” said Lezlee Westine, the Council’s President and CEO. “This promotion reflects Lisa’s exceptional background in developing strategic public information initiatives, both nationally and globally, on a variety of issues facing our industry.”

Powers oversees the development and execution of strategic communications and public affairs programs including media relations, issues management and the integration of communications with the needs of the Council’s more than 600 member companies, which manufacture and distribute the majority of cosmetic and personal care products sold in the U.S. Powers joined the organization in 2006 as Vice President, Communications and Public Affairs and was promoted to Senior Vice President in 2012.

Before joining the Council, Powers worked at the Mercury Group where she was responsible for a full spectrum of services from business development and client acquisition, to communications strategy, branding and marketing campaigns, to website and publications management. During that time, Powers developed and executed successful communications campaigns on behalf of the agency’s key clients which included Fortune 500 companies, advocacy and trade associations, political candidates and celebrities.

Powers has served in top communications and public affairs positions throughout her career and has worked with hundreds of national and international news outlets.

She holds an M.A. in Public Affairs/Communications from American University, and a B.A. in Journalism from Temple University.

]]>http://www.spraytm.com/pcpc-promotes-powers.html/feed0Dual Marking & Labeling: How much is too much?http://www.spraytm.com/dual-marking-labeling-how-much-is-too-much.html
http://www.spraytm.com/dual-marking-labeling-how-much-is-too-much.html#commentsTue, 07 Jan 2014 16:01:13 +0000http://www.spraytm.com/?p=5505The deadline for marking and labeling of products according to the U.S. Occupational Safety & Health Administration’s (OSHA) Globally Harmonized System for Classification & Labeling of Chemicals (GHS) Hazard Communication Standard (HazCom 2012) is not far off, but a number of companies have already begun the transition to the new standard. Unfortunately, there is some confusion as to whether GHS marking and labeling is required on transportation packaging or not.

OSHA initially prohibited the use of both the U.S. Dept. of Transportation (DOT) Hazard Warning Labels and the GHS pictograms for the same hazard, but letters of interpretation issued by both agencies now permit the use of dual marking and labeling, but this leads to the inevitable question, “How Much is Too Much?”

Shipped Containers

OSHA defines, under the new Hazard Communication Standard (HCS), a “shipped container” as “…any container leaving the workplace.” Under the HCS, an employer is required to label a hazardous materials “immediate container,” but the standard does not require labels on the outside shipping containers.

However, single packaging such as pails, drums, totes and cargo tanks would meet OSHAs definition of an “immediate container,” and should therefore be labeled in accordance with 29 CFR 1910.1200(f)(1), which requires the following:

Product Identifier

Signal Word

Pictogram

Hazard Statements

Precautionary Statements

Name, address, and telephone number of the chemical manufacturer, importer or other responsible party

Indeed, OSHA stated in an interpretation letter (Intercontinental Chemical Corp., 12/20/12), that “…DOT requires diamond-shaped labels for the transport of chemicals, including chemical drums, chemical totes, tanks or other containers [and] … these containers will also be the hazardous chemical’s immediate container, and therefore, both a DOT and an HCS label are required [and that] …. each container of hazardous chemicals leaving the workplace must be labeled in a way that does not conflict with the requirements of the Hazardous Materials Transportation Act, 49 U.S.C. 1801 et seq.”

So far, so good! Now, here comes the confusing part: Appendix C.2.3.3 of the Hazard Communication Standard 2012 (HCS 2012) states that “…[w]here a pictogram required by the Dept. of Transportation under Title 49 of the Code of Federal Regulations appears on a shipped container, the pictogram specified in C.4 for the same hazard shall not appear.”

This implies that the pictogram which is similar in design to the required hazard warning label (e.g., GHS02 and Flammable Liquid 3 label) should not be used. However, in the case of pictograms that have no corresponding DOT hazard warning label, such as the exclamation (GHS 07) and health hazard (GHS 08), these pictograms should appear, when appropriate.

Interpretations Issued

Since the HCS 2012 final rule was published, both OSHA and DOT have issued letters of interpretation that permit the use of both pictograms and DOT hazard warning labels on the package simultaneously.

OSHA stated in its Dec. 20, 2012 Interpretation Letter to Intercontinental Chemical Corp., that “…DOT does not view the HCS 2012 pictogram as a conflict with the requirements of the Hazardous Materials Transportation Act, and for some international trade, both the DOT and the HCS 2012 pictograms may need to be present on the label. Therefore, OSHA intends to revise C.2.3.3. In the meantime, OSHA will allow both DOT and HCS 2012 pictograms for the same hazard to appear on the label.” This interpretation vacates the prohibition against dual marking for the same hazard.

DOT’s Letter of Interpretation of April 5, 2013 to Monsanto Co. states that the “…prohibition provided in [49 CFR] § 172.502(a)(2) is intended to limit the potential for dilution of the hazard warning communication provided by the appropriate hazardous materials placards [and]…the GHS marks and labels provide additional hazard communication and are not extraneous markings; and the difference between the hazardous materials placards and GHS marks and labels is such that there is a low likelihood of confusion. Therefore, it is the position of this office [PHMSA] that the described display of the GHS marks and labels … would not constitute a violation of [49 CFR] § 172.502(a)(2).”

A copy of these interpretations may be obtained by contacting the author or from the following URL’s:

It is important to note, however, that DOT does specifically address the type of packaging in its response, leaving the issue of dual marking still open to interpretation on combination packaging, comprised of an inner packaging (“immediate container”) and an outer packaging.

Although the type of packaging addressed in Monsanto’s petition for clarification is an International Maritime Organization (IMO) cargo tank, a single bulk packaging for DOT’s purposes, or an “immediate container” for the purposes of OSHA, the response makes no reference to the packaging type, thereby implying that dual marking provides additional hazard communication and would, therefore, not be “extraneous markings” on combination packaging.

OSHA’s interpretation does refer to the marking on the hazardous chemical’s “immediate container,” thereby implying that dual marking would apply only on DOT single packaging such as pails, drums, totes and tanks.

Although the DOT and OSHA now allow the GHS and DOT labels for the same hazard, these agencies are limited in jurisdiction to that of the U.S. only. It is possible for other regions, such as the European Union, to interpret the GHS standard differently and prohibit the redundant marking. In these cases, the use of dual or redundant marking may be too much, causing the shipment to be frustrated and unnecessarily delayed.

Recommendations

Until the subject of dual marking is sufficiently addressed in a subsequent rulemaking by OSHA and/or the GHS’ developers, I would recommend the following:

Single Packaging

1. Apply the required GHS marks and pictograms on single packaging (e.g., pails, drums, totes, tanks), for different hazards, in addition to the marks, labels, placards, panels and other markings required by DOT.

2. Where the GHS hazard pictogram is the same as the DOT hazard warning label (e.g., GHS02,

Flammable Liquid) there is no need to duplicate the marking. This recommendation is consistent with Annex 7 of the GHS standard. Even though OSHA and DOT allow both to be used, OSHA and DOT jurisdiction do not extend to other countries or regions (e.g., the European Union) where there may be a difference in interpretation.

3. Adjust the pictograms’ size to distinguish them from the required transport labels. The size of the non-transport pictograms should be proportional to the size of the text of the other label elements. This would generally be smaller than the transport-related pictograms, but such size adjustments should not affect the clarity or comprehensibility of the non-transport pictograms.

Combination Packaging

1. Apply all of the required GHS marks and pictograms on the inner receptacles (e.g., aerosol cans, glass bottles, metal cans) in combination packaging, even though the outer packaging may have a transport label which is the same as the inner packaging.

2. The size of the GHS marks and pictograms should be proportional to the size of the other label elements and the size of the receptacle. It is important to note that other agencies (e.g.,

Consumer Product Safety Commission) have minimum font and warning label sizes that are proportional to the size of the inner packaging.

3. Apply only the required DOT marks and labels on the outer packaging, as described in Annex 7 of the GHS standard.

Overpacks Containing Damaged Packages

1. Overpacks which contain damaged packaging (single or combination) should be marked as for single packaging (see Single Packaging above). SPRAY

]]>http://www.spraytm.com/dual-marking-labeling-how-much-is-too-much.html/feed0Pitting corrosion in sprays is caused by a variety of factorshttp://www.spraytm.com/pitting-corrosion-in-sprays-is-caused-by-a-variety-of-factors.html
http://www.spraytm.com/pitting-corrosion-in-sprays-is-caused-by-a-variety-of-factors.html#commentsTue, 07 Jan 2014 15:52:32 +0000http://www.spraytm.com/?p=5500“What causes pitting corrosion?” is a very common question for spray packaging. There are multiple factors that could cause pitting corrosion in spray packaging. Let’s start the discussion by defining pitting corrosion.

Corrosion Basics:Definition of pitting corrosion
Pitting corrosion is a specific type of localized corrosion, and localized corrosion is a type of corrosion that occurs in small occluded areas where diffusion of your bulk formula into the occluded area is restricted. Occluded areas include the a) bottom and top double seams in three piece welded containers and two piece drawn and ironed containers, b) the crimp area between the valve cup and container curl and c) a growing pit.
Notice that the weld in three-piece welded aerosol containers is not included in the list. The overlap formed by the weld is too shallow to create an occluded area.
Pitting corrosion forms an occluded area after the pit has reached a certain depth, referred to as the critical depth. There is a wide range of critical depths, and the magnitude of the depth is determined by a) your formula chemical composition and b) the type of spray package metal, and c) the type of surface treatment on the spray package metal (e.g., uncoated tinplate or a polymer coating).
The most common causes for spray package pitting corrosion are:

Inclusions in the spray package metal

Crystal defects in the spray package metal

General corrosion of the spray package metal

Holes in tin coatings

Transforming an internal coating into a semi-permeable membrane

Notice that holes in internal coatings are not on the list. A hole in a coating is insufficient to cause pitting corrosion. A large area of the coating surrounding the hole must become a semi-permeable membrane or completely fail as a barrier in order for a hole in a coating to cause pitting corrosion.

Inclusions in the spray package metal
The metals used for spray packaging are mixtures of different metals and non-metals. The various ingredients are added to the molten base metal (iron or aluminum). The various ingredients are added to give the package material its properties, such as strength.
When the molten metal cools some of the ingredients become insoluble and precipitate out of the metal as particles. These particles are called inclusions, and inclusions on the surface of the package metal are possible sources for pitting corrosion.

Crystal defects in the spray package metal
Metal atoms are arranged in one or more repeating three-dimensional patterns. However, the atom patterns are not perfect and defects, such as missing metal atoms occur in the crystal structure of the package metal. There are millions of metal crystalline defects in a square centimeter of metal surface. Under the appropriate conditions some types of crystal defects are possible sites for pitting corrosion.

General corrosion of the spray package metal
General corrosion produces a layer of corrosion product on the surface of spray package metals. This layer is porous and has a very non-uniform thickness. The porosity and non-uniform thickness causes non-uniform diffusion of materials through the corrosion product layer. The non-uniform diffusion over the surface of the package metal could also cause pitting corrosion under the general corrosion product layer.

Holes in tin coatings
Tinplated steel is steel sheet metal with a thin layer of metallic tin on both sides of the sheet. The tin layer is not perfect and has holes that expose either the iron-tin alloy layer between the tin and the steel, or the holes expose the base steel.
Certain formula compositions will cause the tin layer to pit the steel base wherever steel is exposed by a hole in the tin layer. My experience has been that this type of pitting corrosion is not as common as other types of pitting corrosion.

Transforming of an internal coating into a semi-permeable membrane
Coatings are actually not barriers between your formula and the spray package metal under the coating. Water, ions and other formula ingredients can absorb into the coating, thereby changing the properties of the coating.
A saturated coating could become a semi-permeable membrane that subsequently allows only specific formula ingredients to pass freely through the coating to the package metal under the coating. In some instances, the material passing through the coating could be significantly more corrosive than your formula and cause pitting corrosion.
The chemical composition of your formula ultimately will determine whether or not spray package metal pitting corrosion is caused by an inclusion, crystal defect, general corrosion, holes in tin or coatings that become semi-permeable membranes.
Please send your questions/comments/suggestions to rustdr@pairodocspro.com. Back issues of Corrosion Corner are available on CD from ST&M. Thanks for your interest and I’ll see you in February. SPRAY

CARB
The California Air Resources Board (CARB) continues to work on finalizing the amendments to the Consumer Products and Aerosol Coating regulation. The fifteen-day notice should be released around the first of the year. After comments are made and CARB staff finalizes the rule, the next step is to send the rule to the Office of Administrative Law (OAL) for review. OAL has thirty days to comment then submit the rule for finalization. If everything goes well, this will all be done by the end of the first quarter.

LVP Research
In addition to this work, the research division is working on the low vapor pressure-volatile organic compound (LVP-VOC) study. The final list for testing has been set. Below are the compounds that will be in the LVP-VOC study.

Next, CARB research will review formulations of products with each of these compounds in them. CARB will also review different categories of products for different use patterns. For example, some products are used where a majority of the product is not emitted into the atmosphere. One example is products that are routinely washed down the drain, such as cleaners. The VOCs from these products are likely not emitted as a result of being in contact with water and processed through a sanitation plant. The next call with the CARB research division will be in early January.

If your company relies on LVP-VOC for your formulations, you need to pay specific attention to CARB’s LVP-VOC study; the outcome could have a significant effect on your product.

Product Dating/Date coding
Date code information needs to be reported to CARB every year by your company if you do not use CARB’s standard date coding. California Section 94512 (b) product dating specifically requires all consumer products to be sold into the state to display the day, month and year the products was manufactured or a code indicating the date. CARB has been increasing their activity on investigating and levying fines for non-compliance of this section.
The date or date-code information shall be located on the container or inside the cover/cap so that it is readily observable or obtainable (by simply removing the cap/cover) without irreversibly disassembling any part of the container or packaging. Information may be displayed on the bottom of a container as long as it is clearly legible without removing any product packaging.
CARB’s standard code that has to be represented separately from other codes on the product container so that it is easily recognizable is the following: YY DDD = Year Year Day Day Day. A manufacturer who uses this standard CARB code to indicate the date of manufacture does not have to report this code.
Failure to register a date code is subject to a fine, which seem to go up every year. Your date code explanation needs to be submitted to Enforcement on an annual basis, on or before Jan. 31 of each year.

OTC
Ozone Transport Commission (OTC) held a meeting on Nov. 14 in Washington, DC, where it voted on a resolution to submit to the U.S. Environmental Protection Agency (EPA). This resolution requests that the EPA adopt the newest Consumer Products Model Rule approved by OTC, as the National Regulation on Consumer Products. This new model rule is significantly more stringent than the current EPA National Rule on Consumer Products. Remember, the EPA National Consumer Products rule was adopted in 1998. Since that time, CARB has had numerous rulemakings and has added many more categories and lowered VOC limits on the existing categories. The OTC model rule does not have all the stringent limits of the CARB rule, but the OTC rule was modeled after an earlier version of the CARB rule.
The issue is that there are parts of the U.S., such as the southeast and numerous states out west, that only have the EPA National Consumer Products Regulation to deal with. By updating the rule to the OTC Model Consumer Products rule, some regional manufacturers or national manufactures that have regional products will be subject to significantly lower VOC limits. The question is whether these states and our consumers need these stringent VOC limits.
At the meeting, the EPA presented an update of its activities and this issue was not on its list. We will need to wait and see if EPA has the manpower to work on updating their regulation. If they decide to work on this rule, we as the Industry, need to ensure enough time is given to comply with the new limits. Spray

As the number of people struggling with heroin and prescription drug addiction continues to grow across the state, police throughout New Jersey are preparing to arm themselves with a tool that could help reduce the number of people who die from overdoses each year.

By early next year, police in Ocean, Hunterdon, Camden and Cape May counties could begin carrying Narcan, an aerosol form of naloxone, which counteracts the effects of heroin and other opioids, buying first responders valuable time to get overdose victims potentially life-saving care, officials said.

“The time frame is extremely critical when you have an overdose and certainly the sooner the intervention is available the better chance for success,” said Rebecca Alfaro, the director of prevention and training with the Governor’s Council on Alcohol and Drug Abuse.

Previously, only hospital staff could administer Narcan, the brand name for naloxone. But it became legal for police officers — and virtually anyone else — to use the drug when legislators earlier this year passed the Opioid Antidote and Overdose Prevention Act, a “good Samaritan” law aimed at protecting those who render aid to overdose victims.

On average, it would take up to 15 minutes for an overdose victim to receive aid from a hospital employee, said Kenneth Lavelle, a doctor and former firefighter who is helping police in Ocean County train to use the drug. Police equipped with naloxone can normally administer a dose within two to four minutes while relatives and friends who have the drug on hand can provide aid immediately.

The drug would be administered just like a nasal spray and can revive people who overdose on heroin or other opiates.

Narcan will be in police cars throughout Ocean County by February, said Al Della Fave, a spokesman for the Ocean County Prosecutor’s Office. Hunterdon County Prosecutor Anthony Kearns said local police officers will also begin carrying the drug next year, and Cape May County Prosecutor Robert Taylor said he has begun discussions with local police chiefs about the use of Narcan.

Camden County Police Chief Scott Thomson said he will take a “very close look” at using the drug early next year, which would make his department the first law enforcement agency in one of New Jersey’s major cities to carry Narcan.

“Anybody who has a loved one who has a problem with drugs really should have this in their house,” Ocean County Prosecutor Joseph Coronato said. “I’ve got mixed emotions. I’m not trying to condone what people are doing. But at the same time, it’s about saving somebody’s life.”

Naloxone can block the effects of an opioid for roughly 90 minutes, Lavelle said. The effects of heroin often last up to four hours so addicts who use naloxone to ward off an overdose will still require medical attention, he said.

Heroin abuse has surged in New Jersey since 2010, as young prescription pill addicts turned to the cheaper street drug after running low on funds for oxycodone and other substances. In Ocean County alone, 107 people have died of fatal drug overdoses this year, and the overwhelming majority of those deaths have been linked to heroin or opiates, Della Fave said.

In 2012, the county saw just 53 fatal drug overdoses.

The number of people admitted to treatment facilities in New Jersey in 2012 grew by 11.4 percent, jumping from 22,757 to 25,356, records show.

While rehabilitation and drug enforcement are still critical to stemming the epidemic, prosecutors said the use of naloxone by police will be key to slowing the number of deaths in the meantime.

“The heroin is so pure here in New Jersey. An unsophisticated user is certainly very prone and vulnerable to overdose,” Kearns said. “The fact is that it’s so inexpensive and it’s not controlled, it’s a drug that every time a person uses it, it’s like Russian roulette.”

The Thames Valley-based waste and recycling company says the new equipment will be installed at its Hazardous Waste Transfer Station at Ewelme in Oxfordshire.

“The Hazpak has huge potential to transform the way the public, commerce and industry handles the disposal of aerosol cans,” says Jonathan Harris, technical general manager of Grundon Waste. “Today’s focus has to be on moving materials up the waste hierarchy, away from disposal towards more recycling. This equipment has the power to make that goal one step closer.”

Harris also says he believes the unit’s capacity will drive more sophisticated return and recycling schemes by major manufacturers, retailers and local authorities.

“At the same time, we will be able to offer manufacturers and industrial customers a much more cost effective, safer and more environmentally-friendly approach for aerosol disposal,” Harris says.

The new Hazpak 6000, one of only two such plants in the U.K. for the disposal of waste aerosols, was developed and manufactured in Canada by the Eko Environmental division of Maclean Engineering.

Eko Environmental says the Grundon team, which already has a smaller Hazpak unit in place at Ewelme, was involved in the design project, ensuring the system meets UK and European legislation and regulations.

Expected to be fully operational by the end of April, the closed-loop system operated by the Hazpak 6000 is designed so that every component is recycled or reprocessed in a safe, oxygen-free environment, with zero emissions released into the atmosphere.

The metal from the cans will be sent for recycling, while liquids (such as hairspray, paint or deodorant) will be separated for recovery or recycling, and the propellants (such as butane or LPG) are collected and used by Grundon to fuel in-house operations and/or generate electricity, the company reports.

The company says the new operation will be able to handle approximately 72,000 aerosols a day on an average eight-hour shift.

In addition to handling aerosols, the Hazpak 6000 will be capable of processing paint tins, oil filters, varnishes, inks and small gas cylinders, Eko Environmental says.

]]>http://www.spraytm.com/grundon-waste-management-in-the-uk-invests-in-closed-loop-aerosol-recycling-system.html/feed0P&G to merge European unitshttp://www.spraytm.com/pg-to-merge-european-units.html
http://www.spraytm.com/pg-to-merge-european-units.html#commentsWed, 18 Dec 2013 18:31:59 +0000http://www.spraytm.com/?p=5407Procter &Gamble (P&G) will merge its Western European unit with its Eastern and Central European units to create one group for the continent. The Indian business unit will also combine with the Middle East and African groups.

P&G currently has five geographic units in North America, Latin America, Asia, Western Europe and CEEMEA (Central and Eastern Europe, the Middle East and Africa). A.G. Lafley, P&G’s CEO, said the reorganization is part of its plan to reduce expenses. More details will be announced in 2014. Some jobs in Europe may be cut as a result of the changes, according to Bloomberg News.

]]>http://www.spraytm.com/pg-to-merge-european-units.html/feed0Dow Chemical considers name change, salehttp://www.spraytm.com/dow-chemical-considers-name-change-sale.html
http://www.spraytm.com/dow-chemical-considers-name-change-sale.html#commentsThu, 05 Dec 2013 17:04:54 +0000http://www.spraytm.com/?p=5332The head of Dow Chemical Co. ( DOW ) said the company might consider changing its name in the wake of detailing plans on Monday to shed the volatile, low-margin commodity chemicals businesses with annual sales of $5 billion that date back to its founding more than 100 years ago.

Dow executives have discussed dropping “Chemical” from its name as part of its migration away from low-margin commodity chemicals such as chlorine used in cleaning products, to focus on higher-value businesses including agricultural seeds and packaging materials.

The move mirrors efforts elsewhere in the industry, notably by rival DuPont & Co., to shed commodity chemicals that are prone to intense competition and price swings, and focus instead on patent-protected businesses that are more resilient in economic downturns.

Andrew Liveris, Dow’s chairman and chief executive, said in an interview the restructured business would be linked by “chemistry rather than chemicals,” noting it had focused recent marketing efforts, such as sponsorship of last year’s summer Olympics in London, on the standalone Dow brand.

“Would I be brave enough?” Mr. Liveris said in reference to changing Dow’s name. He confirmed internal branding discussions have taken place at the world’s second-largest chemical company by sales after Germany’s BASF SE, but added that the company was not yet planning such a move.

The company outlined plans on Monday to exit from 40 facilities at 11 sites producing chlorine, epoxy and other commodity chemicals, which face intense competition from producers in Asia. Dow plans to sell, spin off or create joint ventures for those operations, which employ around 2,000 staff world-wide, 70% of them along the U.S. Gulf Coast. They generate $4 billion in external sales and another $1 billion in internal transfer.

The company has already shed $10 billion worth of business lines since 2009, much of which involved shrinking the commodity plastics business. In October, Dow announced a target to raise between $3 billion and $4 billion from additional sales over the next two years.

“We have had a lot of [early] interest,” said Mr. Liveris of the latest sales plan. “We judged this to be a good time…to open up the doors.”

Analysts said interest is expected to come from companies looking to leverage access to cheap U.S. natural gas produced from shale formations by acquiring some or all of the Dow facilities.

“I think they have to do it in pieces,” said H. Cooley May, analyst at Macquarie Capital (USA) in Houston, who cited U.K.-based Ineos Group Ltd., Brazil’s Braskem and India’sReliance Group as potential suitors or partners.

If the disposals take place over the next 12 to 24 months as planned, Dow, which had sales of $56.8 billion in 2012, will have shed nearly a quarter of its business by revenue in five years.

Mr. May said investors may still be looking for further exits from commodity products.

“I would not be surprised if we’ve still to see them cutting [more] plastics and performance materials,” he said.

Mr. Liveris said Dow was “getting very close” to determining the future size and shape of its portfolio, with the latest disposal plans.

Dow is the largest U.S. chlorine producer by volume, and the latest restructuring would see it largely exit a business that underpinned its founding in 1897 when Herbert Henry Dow, who commercialized a method to extract brine-based chlorine to make bleach.

Dow started to shrink its commodity business in 2005, with a goal of reducing exposure from more than 50% of sales to just 20%. But the financial crisis of 2008 almost derailed that plan when Dow’s $9 billion purchase of rival Rohm & Haas gave it high-margin specialty chemicals but saddled the company with massive debt.

“People were writing us off, yet we pulled it off,” Mr. Liveris said.

Dow has sworn off more acquisitions since the Rohm & Haas deal, focusing on reducing debt and boosting shareholder returns, and has no plans to alter that strategy with the expected proceeds from exiting commodity chemicals.

Most of the new set of planned disposals are focused at the U.S. Gulf Coast, but Mr. Liveris said Dow’s domestic footprint would still expand as new facilities designed to exploit cheap shale gas come online to produce higher value products.

]]>http://www.spraytm.com/dow-chemical-considers-name-change-sale.html/feed0Aerosol packaging consultant Ian Gecker retireshttp://www.spraytm.com/aerosol-pacaging-consultant-ian-gecker-retires.html
http://www.spraytm.com/aerosol-pacaging-consultant-ian-gecker-retires.html#commentsThu, 05 Dec 2013 16:57:38 +0000http://www.spraytm.com/?p=5328Ian Gecker, of aerosol packaging consultancy Ian Gecker & Associates, LLC, is retiring after 50 years in the aerosol industry. Gecker is a Past President of the Western Aerosol Information Bureau (WAIB), served on its Board for six years and was a founding Board Member in 1978.
]]>http://www.spraytm.com/aerosol-pacaging-consultant-ian-gecker-retires.html/feed0Utah set to ban aerosols with high hydrocarbon concentrationshttp://www.spraytm.com/utah-set-to-ban-aerosols-with-high-hydrocarbon-concentrations.html
http://www.spraytm.com/utah-set-to-ban-aerosols-with-high-hydrocarbon-concentrations.html#commentsThu, 05 Dec 2013 16:43:41 +0000http://www.spraytm.com/?p=5324

By PAUL FOY, Associated Press

A board of state regulators adopted a set of comprehensive plans Wednesday to cut chronic air pollution along the heavily populated urban corridor of northern Utah.

The plans won’t bring relief for years, however, and a group of Utah doctors and other clean-air advocates lambasted the Utah Air Quality Board for failing to move more aggressively. They also criticized the board for approving major expansions at Salt Lake oil refineries in the meantime.

By official accounts, Utah’s mandatory emission reductions aren’t designed to achieve federal air quality standards until 2019 at the earliest. But by then, the state may have to find ways to cut emissions further as the federal government tightens air-quality standards.

Air pollution has summer and winter seasons in Utah that are associated with high-pressure systems that can trap polluted air in bowl-shaped mountain basins. The winter season opened with Utah’s first major winter storm Tuesday, when counts of fine soot in the air skyrocketed along the heavily populated Wasatch Front. For reasons not fully understood, snow amplifies the effect of air pollution.

Utah’s air was bad enough last winter to prompt three rallies on Utah’s Capitol Hill. Northern Utah had 22 days of toxic air as weather systems trapped murky air close to the ground. More recently, Utah earned “F” grades from the American Lung Association.

The Utah Air Quality Board adopted regulations that for the greater Salt Lake region are supposed to reduce emissions by 247 tons a day. It followed up at the same meeting Wednesday with approval for separate plans in Utah and Cache counties.

The regulations cover everything from industrial smokestacks to household products. Utah is banning the sale of aerosols like hair spray with high concentrations of hydrocarbons. Another regulation requires hamburger restaurants to install catalytic converters for open broilers.

Most of northern Utah’s air pollution, however, comes from tailpipe emissions, and regulators say they can’t do much about that.

Critics say Utah didn’t lean heavily enough on industry for emissions cuts. The plans give major polluters until 2017-19 to phase in more effective smokestack controls.

“We can’t wait until 2019,” said Thomas Plustwik, a Salt Lake City resident who conducts home-energy audits for Greenify Energy Savers. “I’m holding out on having a family myself. I don’t want my wife to be pregnant breathing this air.”

Air pollution assaults the human body in ways that have only recently been made clear by medical studies, and it hits children, infants and developing embryos especially hard, said Brian Moench, president of Utah Physicians for a Health Environment.

By waiting until 2019 to achieve federal air-quality standards, “we’re condemning tens of thousands of children to poor health,” he said.

Exposure to toxic air can damage chromosomes that get passed on to ensuing generations, he said. It also can trigger latent disease in people, he said.

Regulators said they were doing the best they can to clear Utah’s air.

“This is four years of work, and it’s all coming to fruition,” said Steven Sands, chairman of the Utah Air Quality Board and external-relations chief for Kennecott Utah Copper Corp., one of Utah’s major polluters.

The California Air Resources Board (CARB) continues their work on Consumer Products. On Oct. 23, the CARB research division held its first meeting on the Low Vapor Pressure (LVP) Research Study Contracts to be conducted by University of California, Riverside (UCR) and the University of California, Davis (UCD). During the meeting, both universities explained the activities they will preform on the LVPs during their individual studies. After the presentations, the universities requested a list of chemicals to be tested from the Industry. Industry has developed a list and presented it to CARB. We hope, as we go to press, that by the end of November this list will have been completed.

On Nov. 5, CARB held another meeting to discuss finalization of the Sept. 26 board hearing amendments and a preview of future activities. CARB should release the fifteen-day notice for the board hearing soon. As far as future activities go, the next steps for CARB will be to develop surveys for the industry. Likely the industry will work with CARB through the first part 2014. Then the survey will likely be released around the middle of 2014.

Therefore, next year we will be busy with developing survey forms and monitoring LVP research.

A reminder: as of the end of this year the following changes at CARB take place (see charts). Remember, any product made before this deadline and properly date coded can be sold for three years.

Green Chemistry

Here are some updates for the Safer Consumer Products Regulation that went into effect on Oct. 1, 2013. The Dept. of Toxic Substance Control (DTSC) will release the priority products by at least April 1, maybe earlier. The DTSC has indicated that they will likely only work on three products/chemical combination at the beginning, then possibly expanding the total to five.

A Guidance Document for the Alternative Assessment (AA) Part One should be released at the end of 2013 or early 2014. The Part One guidance document covers the first phase of the AA, with Part Two, covering the second phase of the AA, is planned for release in the first quarter of 2014.

A common joke is that the Globally Harmonized System (GHS) is neither Global nor Harmonized. It is not harmonized due to the implementation differences in many countries. It is not global because it has yet to be implemented in various jurisdictions. The past few months have brought us closer to meet the global part of GHS, but further away from harmonization.

EU Releases 4th ATP of the EU CLP Regulation

The European Commission has issued its 4th Adaptation to Technical Progress (ATP) of its GHS-based Classification, Labeling & Packaging (CLP). The 4th ATP is a particularly important change as it aligns CLP with the 4th edition of the GHS Purple Book (Like CLP before this change, Hazcom 2012 is aligned with the 3rd edition of the Purple Book).

The regulations can be downloaded at: http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=OJ:L:2013:149:0001:0059:EN:PDF

The deadline for compliance is Dec. 1, 2014 for pure substances and June 1, 2015 for mixtures.

This is a very important change for aerosol companies for one reason—a new category has been created to deal with non-flammable aerosol products. If your company had aerosol products that did not fall under Category 1 or Category 2 Flammable Aerosols, they will now be considered a Category 3 Non-Flammable Aerosol. Your labels and SDSs will need to be updated to reflect this, as there are new associated hazard and precautionary statements for products falling under Category 3.

Fortunately, you will not need to add a pictogram on your labels for non-flammable aerosols. You will, however, need to add the new hazard statement H229, “Pressurized container: May burst if heated”. Furthermore, the following precautionary statements are required: P210: “Keep away from heat/sparks/open flames/hot surfaces—No smoking”, P251: “Pressurized container—Do not pierce or burn, even after use” and P410+P412 “Protect from sunlight. Do not expose to temperatures exceeding 50°C/122°F.”

There are a host of other changes, including additions and deletions of hazard and precautionary statements as well as new exemptions for small containers. A new GHS classification has been created for Chemically Unstable Gases.

This is not the last time CLP will be updated. The final version of the next (5th) ATP is expected to come into force Jan.1, 2015 and will update the classifications for 40+ substances, including nitrobenzene and vinyl acetate.

If you have European compliant labels or SDSs, there are a few things you should be doing now. The first is to see if any of your products are eligible for the small container exemptions, as they are very convenient. Second, make the necessary changes to your products that are either unstable gases or non-flammable aerosols. Finally, amend your SDSs and labels to be compliant with the new P-statement introduced in this regulation.

Canadian GHS Progress Marches On

Canada is still without a GHS-based replacement for its Workplace Hazardous Materials Information System (WHMIS), but progress continues. A proposal was released to the generic public by Health Canada on June 29, 2013. There was a comment period that ended Sept. 15, 2013. The issues we presented to Health Canada were based on the need for at least a two-year transition period and further harmonization with U.S. Hazcom 2012 in areas such as disclosure of mutagenic ingredients.

The largest concern our colleagues and clients had was with the proposal’s requirement that exact concentration percentages be used on SDSs, except for cases of batch-to-batch variation.

A number of our clients have asked us if they should be preparing Canadian GHS based documents today. I would highly advocate caution and suggest waiting. The final rules will change from these, so any work you do now will likely need to be altered in the future.

We are now awaiting a final rule, which we expect to be released in the first six months of 2014. We will keep you informed on the progress of GHS implementation in Canada. SPRAY

In the July 2013 issue of Spray, I detailed the increase in minimum and maximum civil penalties published in the U.S. Dept. of Transportation’s Pipeline and Hazardous Materials Safety Administration (PHMSA) final rulemaking, HM-258, on April 17, 2013. In that article I stated that “the maximum civil penalty, as amended by the Moving Ahead for Progress in the 21st Century Act (MAP-21) signed into law on Oct. 1, 2012, is increased from $55,000 to $75,000 for each violation. The maximum civil penalty is increased from $110,000 to $175,000 for each violation that results in death, serious illness or injury to any person, or substantial destruction of property.”

Well, just a few weeks ago (Oct. 2, 2013 – 78 FR 60726), PHMSA published another final rulemaking, HM-258C, which revises the agencies’ policy statement with respect to the baseline assessments for frequently-cited violations of the Hazardous Materials Regulations (HMR). The final rule substantially increases the baseline assessments and clarifies additional factors that affect the penalty amounts. The baseline assessments are used by the agencies’ field operatives and attorneys as guidelines when assessing a civil penalty against an alleged violator.

The increase in the baseline assessments for those frequently cited violations of the HMR reflect inflationary and statutory adjustments as well as the safety risks associated with each type of material. For example, offenders that improperly prepare Packing Group I (most dangerous) materials can expect to receive penalties that are considerably higher (up to five or six times more) than those who improperly prepare Packing Group III (least dangerous) hazardous materials.

In the 20-page rulemaking, PHMSA lists those sections of Title 49, Code of Federal Regulations (49 CFR) that are most frequently-cited in civil penalty actions, some of which are highlighted in the table on the facing page.

The baseline assessments described at the bottom of this article are only a fraction of the initial penalty amounts that are outlined in the final rule. The baseline assessments are typically adjusted up or down by as much as 25-50%, depending upon the aggravating and mitigating circumstances of the case. Also taken into consideration is the alleged violator’s ability to pay the penalty and ability to stay in business after the fine is levied, as well as “…other matters that justice may require.” The last factor, “other matters,” simply means that the regulatory agency may wish to make an example of the offender and use the case as a warning to other potential violators against those types of infractions.

In my July 2013 article in Spray, I offered some very good advice to the reader, which I now repeat so as to reinforce the importance of compliance with the regulatory requirements for the transport of hazardous materials and to avoid these potentially costly and damaging penalties:

When in Doubt, Leave it Out! If you’re not sure, don’t ship. Call and ask for assistance. SPRAY

The surfaces of spray package materials are far from perfect. The metal-making process, the processes used to fabricate metal containers, coating application processes and the foil lamination formation process often produce surface anomalies that could be mistaken for corrosion, or thought to be the starting-point for corrosion.

Let’s take a look at the more common surface anomalies that are found in various types of spray packages.

Chairman, the Plastic Aerosol Research Group (PARG), an affiliate of The Consumer Specialty Products Association (CSPA)

The aerosol marketplace is always looking for innovation. Consumers demand it, and competition is always a friend to innovation where it allows a gain in market share. Although the plastic container has been elusive as an aerosol container, it is now expected in the marketplace. While our customers and consumers will invariably adopt new innovative products and accept the advantages that aerosols have delivered for decades, plastic is an opportunity to bring a new look with new advantages to the marketplace. As an industry, and within the global marketplace, aerosol products need to evolve to meet the needs of our consumers in order to remain at the forefront of innovation.

The aerosol industry is growing and expanding into new nations and markets every year. At about 13 billion units annually, diversifying our container portfolio will continue this growth trend. This is critical to stay the tide of market pressure from less regulated products. Plastic aerosol containers represent a platform from which to show consumers new innovative design options or showcase completely new products.

Setting the Stage

Options for plastic aerosol containers are now more specified, giving the industry a clear process toward the marketplace. One of the original standards for modern plastic aerosol packaging is British Standard BS 5597:1991, created by a committee for the Packaging Freight Containers Standards Policy Committee in 1991. This standard laid the recent framework for inventors to utilize in the development of a plastic aerosol container. Although several attempts to market plastic aerosol containers were initiated in the 1960s, none have sustained shelf presence until recently.

Balea Shave Foam

A significant driver allowing today’s plastic aerosol container is the technical evolution in the injection stretch blow molding (ISBM) process. ISBM improvements to support the conversion of carbonated soft drinks out of glass and into plastic significantly drove the quality and consistency of wall orientation and other process controls that are now being leveraged into the aerosol bottle. Leveraging the improvements in the ISBM bottle manufacturing process, several companies have worked to develop aerosol bottles. These aerosol bottles supported the request of a “Special Permit” (SP) allowing the distribution of plastic aerosol containers to the U.S. Dept. of Transportation (DOT) Pipeline & Hazardous Materials Safety Administration (PHMSA). The PHMSA decided in 2009 to amend section 173 of the Federal Register (Vol. 74) permitting distribution of plastic aerosol containers. Discussion within the code-change preamble is the understanding that the ISBM technology has advanced and that there was no evidence that an issue had been seen in the SPs for plastic aerosol containers to date.

click on image for larger view

Within the discussion of this amendment it is argued that approval of plastic

aerosol containers would also help “enhance international harmonization and provide relief to the regulated community by removing the need for specialpermits”. In this code change, PHSMA set the parameters for a non-specified and anew “2S” specified bottle. Included in the PHMSA code are specifications concerning the shipping papers, labeling, marking and packaging requirements for transportation of plastic aerosol containers. Retaining focus on the container, we can pull from the PHSMA literature characteristics necessary for the distribution of a plastic aerosol. The overriding responsibility is to assure equivalent safety in the marketplace as authorized packaging. General provisions constrain the non-refillable aerosol container to a maximum diameter of 3″, capacity to one liter (1000ml) and pressure to a maximum of 160 psig at 130°F.

Pulling directly from PHSMA 49 CFR these areas should be considered:

178.33b–6 Manufacture.

(a) Each container must be manufactured by thermoplastic processes that will assure uniformity of the completed container. No used material other than production residues or regrind from the same manufacturing process may be used. The packaging must be adequately resistant to aging and to degradation caused either by the substance contained or by ultraviolet radiation.

And

178.33b–7 Design Qualification Test.

(a) Drop Testing.

(1) To ensure that creep does not affect the ability of the container type to retain the contents, each container type shall be drop tested as follows: three groups of twenty-five filled containers shall be dropped from 1.8m on to a rigid, non-resilient, flat and horizontal surface. One group must be conditioned at 38 °C (100 °F) for 26 weeks, the second group for 100 hours at 50 °C (122°F) and the third group for 18 hours at 55 °C (131 °F), prior to performing the drop test. (2) Criteria for passing the drop test: the containers must not break or leak.

§ 178.33b–8 Production Tests.

(a) Burst Testing.

(1) One out of each lot of 5,000 containers or less, successively produced per day must be pressure tested to destruction and must not burst below 240 psig. The container tested must be complete as intended for transportation.

(2) Each such 5,000 containers or less, successively produced per day, shall constitute a lot and if the test container shall fail, the lot shall be rejected or ten additional containers may be selected at random and subjected to the test under which failure occurred. These containers shall be complete as intended for transportation. Should any of the ten containers thus tested fail, the entire lot must be rejected. All containers constituting a lot shall be of like material, size, design construction, finish, and quality.

(b) Leak Testing. (1) Each empty container must be subjected to a pressure equal to or in excess of the maximum expected in the filled containers at 55 °C (131 °F) or 50 °C (122 °F) if the liquid phase does not exceed 95 percent of the capacity of the container at 50 °C (122 °F). This must be at least two-thirds of the design.

Moreover, these requirements were derived in an effort to assure each container is robust. The time frame and breadth of testing is rigorous. Of course, each manufacturer or marketer must review the most current regulations managing products placed into the marketplace in order to retain the high standards of products in the marketplace today.

Manufacture & Storage of a Plastic Aerosol Container

Just because one arm of the regulatory process moves its position doesn’t assure that coordination across regulating bodies can be anticipated. The PHMSA modifications were a boost to the distribution of plastic aerosol containers. However, as important as this move was to the industry, it wasn’t all-inclusive. The PHSMA provided direction toward distribution, but codes for the manufacture and storage retained earlier limitations.

Realizing the inconsistency in code modifications, industry engaged to assist in development of data that would help direct the code-setting bodies for manufacturing and storage codes. To this end, the Plastic Aerosol Research Group, LLC, (PARG) was formed through the Consumer Specialty Products Association (CSPA) Product Ingredient Review (PIR) program. PARG was chartered to engage with industry experts at the National Fire Protection Association (NFPA) and United Laboratories (UL), among others, to determine what would be needed to support code change.

PARG constructed and executed a testing plan to assure good science was employed in the determination of what product/package combinations could be managed by the majority of fire safety systems currently in place for aerosol product storage facilities. In this initial testing scheme, an array of products were fire tested in plastic containers. The products ranged across heats of combustion and propellant concentrations with and without bag-on-valve (BOV) options inside the test variables. The results of these fire tests and other large volume fire tests shared with PARG were compiled and shared with the CSPA. Data from the PARG testing showed the ability to manage a set of product package formulations.

With this data in hand, PARG showed that products with a low order of flammability could safely move to the marketplace. With the advocacy of CSPA, the industry proposed amendments to NFPA 30B and the International Code Council (ICC) through the International Fire Code Council (IFC) authorities. Paramount across code authorities were concerns around the product formulations within a plastic aerosol container and potential for management of a fire event. A white paper was developed showing the results of the fire testing performed and this data was shared with NFPA and IFC/ICC code officials.

At this time the PARG requested code modifications have received initial concurrence across NFPA and ICC/IFC. Principle criteria for storage are based upon a reduction in flammability and specifically need to meet these requirements.

Aerosol products in plastic containers larger than 118 ml (4 fl. oz.) shall be considered to be equivalent to Class III commodities, as defined in NFPA 13, Standard for the Installation of Sprinkler Systems, where any of the following conditions are met:

(a) Base product has no fire point when tested in accordance with ASTM D 92, Standard Test Method for Flash and Fire Points by Cleveland Open Cup Tester, and nonflammable propellant.

(b) Base product has no sustained combustion as tested in accordance with “Method of Testing for Sustained Combustibility”, Title 49 Code of Federal Regulations, Part 173, Appendix H and nonflammable propellant.

(c) Base product contains up to 20% by volume (15.8% by weight) of ethanol and/or isopropyl alcohol in an aqueous mix and nonflammable propellant.

(d) Base product contains 4% by weight or less of an emulsified flammable liquefied gas propellant within an aqueous base. The propellant shall remain emulsified for the life of the product. Where such propellant is not permanently emulsified then the propellant shall be nonflammable.

Now we have a set of requirements in place for manufacture, storage and distribution of plastic aerosol containers. PARG will continue to develop data supporting new products as the industry innovates with the plastic package.

North American Industry Opportunity

At this point in the process, we have a path to production, distribution and storage of an aerosol product utilizing a plastic container. Products are on the shelf today in a very limited capacity. As the code modifications progress, we can anticipate more suppliers and marketers on the shelf.

Airopack dispensing system

This is especially true in the North American (NA) marketplace. Evidence of plastic aerosol containers in North America can be traced back to the 1950s, but few have secured a long-term presence (see SPRAY, April 2009). One example of a plastic aerosol container is Procter & Gamble’s Oral-B Brand dental professional fluoride aerosol mousse product. The plastic container utilizes a standard outside crimp valve with a mousse spout. Shipped via professional channels, the product shows long term stability and market success. A few other plastic aerosol bottles can be found in the U.S. marketplace, although we should anticipate more products in the near future. So how will the new products show up?

We should anticipate bottles utilizing standard valve systems, as well as bottles incorporating the BOV system. These packaging options would be consistent with the current metal container options. Plastic aerosol containers also have a piston option for the marketplace. Airopack (see following page) has introduced a plastic aerosol innovation that separates the product and propellant in a piston system. The key to this technology is the incorporation of a patented valving system that manages the pressure between the product cavity and the propellant container. This valve permits a more consistent pressure delivery during the life of the unit. The pressure-containing vessel is at several bar but the valve manages the product-containing area to a desired functioning pressure. Pressure is the primary variable to manage across this package, as is the case in most aerosol systems. Where aerosol products dictate a specific container style in metal, an equivalent option appears to be available in plastic.

Searching for plastic containers outside of the NA marketplace, we see more products on the store shelves. Today, most plastic aerosol products are found in the European marketplace where plastic aerosol containers are currently permitted. These products comply with the current European Aerosol Dispenser Directive (ADD). Current allowance by the ADD is 50-220ml volume, which has permitted products such as Wella’s Salon Professional Mousse to see the market for several years. Other plastic aerosol products have also recently advanced to the European market such as Balea Shave Foam. The European Union (EU) aerosol community is in the process of requesting the European Commission to modify the ADD regulations (see Plastic Aerosols—situation and prospects. Aerosol Europe Vol. 21. 7/8-2013), and these changes will bring global regulations closer, but not equivalent.

Proposed changes to ADD in the EU, if adopted, will increase both the volume (up to 1000ml) and the internal pressure (up to 15 bar for aerosols using non-flammable propellants). There are equivalent requirements in the U.S. as far as drop impact testing, but the restrictions on the flammability characteristics of the product formulation is not consistent between the EU and the U.S. Yet you need to review, understand and follow all of the regional requirements. We also see plastic aerosol containers on the market in Asia and Latin America. We will need to watch how the regulatory requirements evolve in these and other growing aerosol markets.

Barriers to the marketplace

The regulatory enviroment can be a barrier to the marketplace. Once we understand the regional regulatory requirements, we need to then assure freedom to practice.

Intellectual property is another area for the innovator to manage. Patent publications focused on plastic aerosols were rather slow during the 1990s, averaging only about five per year. During the first decade of the 2000s, patent publications focused on plastic aerosols jumped to an averaged 20 per year. This four-fold increase is interesting to understand, as these publications mostly pertain to a more robust knowledge in the blow molding process and materials understanding.

The knowledge necessary to create high pressure thermoplastic bottles that overcome the earlier issues peaked in 2006. The U.S. has lead the way, with the UK and Japan following. Upon review of the patents related to plastic aerosols, the Base, Neck and Body are primary variables. Base geometry (petaloid, hemispherical and champagne) has been described for pressure retention and uniformity. Neck designs and material characteristics are provided to manage growth due to pressure or environmental conditions.

The body of the plastic container has been discussed with respect to pressure management and permeability. While each container will typically provide each component (base, neck and body), the innovator needs to consider earlier work to assure freedom to practice each final design. In order to not repeat others’ past mistakes, become familiar with the innovation history of intellectual property.

The elegance of evolution

Wella Salon ProfessionalVolumize mousse

What can be deduced from the regulations and the patent literature is that there is significant interest in a plastic aerosol container. Why? Is it the elimination of rust in damp environments? Could it be the ability to shape an aerosol container differently than we can shape metals today? Perhaps it’s the ability to have transparency that isn’t available in metals? Maybe its driven by the lighter weight of the plastic container compared to a metal or glass unit of equivalent size? In the end, I believe it will be a continuous mixture of all of these factors. The elegance of this evolution in the aerosol marketplace is that we should have a growth in product introductions. Certainly, there will be some movement of products from metal to plastic but we should consider the overall potential for growth. The process of applying this option into markets will surpass what any one of us could consider today. The marketplace will drive us to new places and drive new ideas for what an aerosol container may deliver. Considering the inclusion of alternate technologies like BOV, piston containers and new non-flammable propellants like Honeywell’s HFO1234ze, we can see the palette is wider than ever. We are in for an exciting time of innovation across aerosol products. SPRAY

]]>http://www.spraytm.com/expanding-the-aerosol-marketplace-through-plastic-innovation.html/feed0CCL Industries to permanently close Canadian aerosol manufacturing planthttp://www.spraytm.com/ccl-industries-to-permanently-close-canadian-aerosol-manufacturing-plant.html
http://www.spraytm.com/ccl-industries-to-permanently-close-canadian-aerosol-manufacturing-plant.html#commentsFri, 22 Nov 2013 19:00:42 +0000http://www.spraytm.com/?p=5135 CCL Industries Inc. announced that it plans to permanently close its Canadian aerosol manufacturing operation commencing in the first half of 2014 and completing no later than mid-2015.

Geoffrey T. Martin, President & CEO of CCL Industries said, “It is with great regret that we are announcing this news. Our operation in Ontario now exports its entire output into the United States; distance from key customers and the step change rise of the Canadian dollar over the last decade combined to significantly impede competitiveness. The plant has been unprofitable since 2009 and posted sizable losses during the economic crisis years. Although results improved in 2012 and 2013, the operation continues to make losses; consequently we feel it is now time to make this difficult decision.”

Mr. Martin commented, “In addition to appropriate severance and other benefits, we will do our very best to help the 170 employees at the site develop their personal transition plans. Many of them have long tenure with CCL so early notice of the closure gives reasonable time to consider options. These will include outplacement assistance embracing, where possible, international transfers within CCL Container and domestic opportunities at our CCL Label and Avery business units as we simultaneously expand their manufacturing operations in both Toronto and Montreal.”

Mr. Martin continued, “CCL Container will consolidate the sales volume from the Canadian plant into its existing operations in the United States and Mexico, investing approximately $25 million in required capacity and infrastructure additions at its Hermitage, Pennsylvania and Guanajuato sites over 2014 and 2015. This includes the previously announced new aerosol production line planned for installation in mid-2014. The Company will record a pre-tax one-time restructuring charge of $11 million during the fourth quarter of 2013 to provide for the closure costs with approximately 40% in non-cash asset write downs and the balance largely in employee severance. In addition, we expect to expense approximately $4 million from mid-2014 through the first half of 2015 in other one-time transition costs. CCL Container is targeting an increase of $10 million to its current annualized EBITDA run rate of approximately $30 million when the consolidation is completed in mid-2015.”

Mr. Martin concluded, “We firmly believe this decision was essential to optimize the CCL Container supply chain footprint and cost position to best service our important Home & Personal Care customers, all of which are now located in the United States and Mexico.”

]]>http://www.spraytm.com/ccl-industries-to-permanently-close-canadian-aerosol-manufacturing-plant.html/feed0Ball to Consolidate North American Aerosol Can and End Capacityhttp://www.spraytm.com/ball-to-consolidate-north-american-aerosol-can-and-end-capacity.html
http://www.spraytm.com/ball-to-consolidate-north-american-aerosol-can-and-end-capacity.html#commentsFri, 15 Nov 2013 17:48:15 +0000http://www.spraytm.com/?p=5111Ball Corporation announced that it will cease production at the company’s Danville, Ill., steel aerosol packaging manufacturing plant during the second half of 2014. Ball will redeploy the plant’s assets to other existing company facilities and will continue to supply the plant’s customers.

The Danville plant produces three-piece welded aerosol cans and ends for household products customers. Ball will provide the plant’s 47 employees with outplacement services, severance pay and other benefits, in accordance with company policies and the effects bargaining process. Danville employees can apply for open positions within the company.

Ball will record an after-tax charge of approximately $7 million for this closure, the majority of which will be recorded during the fourth quarter of 2013.

]]>http://www.spraytm.com/ball-to-consolidate-north-american-aerosol-can-and-end-capacity.html/feed0Cobra Plastics hires Director of New Business Developmenthttp://www.spraytm.com/cobra-plastics-hires-director-of-new-business-development.html
http://www.spraytm.com/cobra-plastics-hires-director-of-new-business-development.html#commentsFri, 15 Nov 2013 17:26:57 +0000http://www.spraytm.com/?p=5091Cobra Plastics Inc. has announced Martin (Marty) Binder as the Director, New Business Development. Marty has thirty years of executive, sales, marketing and general management experience in the consumer packaging industry including food, beverage, pharmaceutical, health and beauty and household and industrial chemical products segments. He has extensive market knowledge both domestically and internationally.
]]>http://www.spraytm.com/cobra-plastics-hires-director-of-new-business-development.html/feed0Procter & Gamble Announces Organizational Changeshttp://www.spraytm.com/procter-gamble-announces-organizational-changes.html
http://www.spraytm.com/procter-gamble-announces-organizational-changes.html#commentsThu, 14 Nov 2013 14:28:24 +0000http://www.spraytm.com/?p=5074The Procter & Gamble Company announced that Dimitri Panayotopoulos, Vice Chairman and Advisor to the Chairman and CEO, will retire from the Company, effective January 2, 2014, after 37 years of service.

Panayotopoulos joined P&G in 1977. He served in sales and general management roles spanning Europe, the Middle East, Africa, and Asia, eventually overseeing all P&G brands as Vice Chair – Global Business Units. As previously announced, he was elected to his current role as advisor to the CEO effective July 1, 2013.

“We appreciate Dimitri’s considerable contributions over his long and successful career, building leading positions for the Company in Egypt and then the Middle East, China, Central and Eastern Europe, and Africa,” said A.G. Lafley, P&G Chairman of the Board, President and Chief Executive Officer. “He concluded his distinguished career by leading our global business units through challenging times.”

P&G also announced that Bruce Brown, Chief Technology Officer, will retire on August 31, 2014, after more than 34 years of service. Until that time, effective February 1, 2014, Mr. Brown has been named Officer on Special Assignment. Kathleen B. Fish, currently Vice President–Research & Development, Global Fabric Care, has been elected Chief Technology Officer, succeeding Mr. Brown, effective February 1, 2014. Ms. Fish will report to A.G. Lafley.

Robert L. Fregolle, Jr., Global Customer Business Development Officer, will retire on June 30, 2014, after more than 36 years of service. Until that time, effective February 1, 2014, Mr. Fregolle has been named Officer on Special Assignment. Carolyn M. Tastad, currently Vice President–Global Market Strategy & Planning and One Go-to-Market Optimization, has been elected Global Customer Business Development Officer, succeeding Mr. Fregolle, effective February 1, 2014. Ms. Tastad will report to Werner Geissler, Vice Chairman–Global Operations, and Mr. Lafley.

“These changes demonstrate the depth and strength of P&G’s leadership bench,” said Mr. Lafley. “Dimitri, Bruce and Bob have each served P&G for more than 34 years and have made a lasting, positive impact on the Company. Kathy and Carolyn are experienced P&G leaders who will continue to strengthen our innovation and go-to-market capabilities going forward.”

Mr. Brown began his P&G career in 1980, and served in Research & Development roles his entire career, culminating in his election to the position of Chief Technology Officer in 2008. At P&G, the Chief Technology Officer is responsible for the Company’s innovation capabilities and global R&D organization. During his nearly six years in this role, Mr. Brown has launched several important innovations and established the key technology platforms that will drive P&G’s innovation programs in the future.

Ms. Fish joined P&G in 1979 and has led R&D teams in most of P&G’s leading core categories over her 34-year career, including Baby Care, Hair Care and Fabric Care. Most recently, she led the R&D team behind the launch of Tide Pods and Downy Unstopables.

Mr. Fregolle joined P&G in 1979. He spent the majority of his P&G sales career outside of the U.S., in leadership roles across Central and Eastern Europe and Asia, before returning to the U.S. to lead P&G’s Global Customer Business Development organization in 2009. During his 36-year career, he strengthened customer relationships across developed and developing markets and significantly increased the reach of P&G’s distribution around the world.

Ms. Tastad began her P&G career in 1983. She has deep experience leading sales and market development organizations for P&G businesses in the U.S., Canada, Europe and globally, and has worked in a range of businesses including deep experience in Health and Beauty.

In addition, P&G announced that Kirk Perry, currently President–Global Family Care, will leave P&G effective December 2, 2013, to pursue other interests. Steven D. Bishop, currently Group President–Global Feminine Care, will be named Group President–Global Feminine and Family Care. Mr. Bishop will continue to report to Martin Riant, Group President–Global Baby, Feminine and Family Care.

]]>http://www.spraytm.com/procter-gamble-announces-organizational-changes.html/feed0Colep and Scitra join forces to manufacture aerosols in the Middle Easthttp://www.spraytm.com/colep-and-scitra-join-forces-to-manufacture-aerosols-in-the-middle-east.html
http://www.spraytm.com/colep-and-scitra-join-forces-to-manufacture-aerosols-in-the-middle-east.html#commentsWed, 13 Nov 2013 16:15:22 +0000http://www.spraytm.com/?p=5070Colep, with headquarters in Europe, and Scitra, a United Arab Emirates based company, part of the Albatha Group, are proud to announce a joint venture agreement to create an aerosol contract manufacturing operation in the UAE. The Joint Venture will operate under the name of Colep Scitra Aerosols.

The parties will invest in expansion and improvement of the existing Scitra aerosol filling plant in Sharjah UAE, aligning it with international standards required by multi-national branded companies in the personal care and home care industries.

The parties will bring their respective expertise and knowledge of the regional and of the international markets to the new venture, thus creating a first class operation which will serve the PAFTA and COMESA countries of the Middle East and Africa.

Speaking about the establishment of this JV, Peter Ingelse, Managing Director of the Consumer Products Division of Colep said: “this new venture with our partners in the Middle East further extends Colep’s ability to serve our customers across the globe and offer supply nearer to their markets.”

Robin Smythe, Managing Director of Albatha Home and Personal Care stated: “ in joining forces with Colep, we will be able to offer to current and future customers; world class manufacturing closer to the market, improved supply chain, shorter lead-times, reduced inventory, and improved reaction times to changing demands.”

Falcon Safety Products Inc. (Falcon), a world leader in compressed-gas technologies and manufacturer of the Dust-Off brand of office and consumer electronics cleaning accessories, announces the hiring of Steve Smith as Senior Vice President of Sales. Smith will be responsible for managing all sales activities in Falcon’s safety and marine horn and Dust-Off® brand markets in the US and Canada. Working closely with Falcon Safety Products President, Phil Lapin, as well as the company’s senior sales team and sales representatives, he will develop, lead, and implement the company’s overall sales strategy & initiatives.

“Steve brings over 25 years of experience in the consumer products industry and the drive that suits Falcon’s company culture,” said Lapin. “He has a comprehensive understanding of selling consumer products to key mass merchandising companies in the US, as well as a proven track record of implementing successful sales strategies.”

Prior to joining Falcon Safety Products, Smith served as Director of Sales at Sportcraft, Ltd. in Budd Lake, NJ, where he was responsible for all e-commerce sales, development and inventory reduction initiatives. He also served as Director of Sales at Zippo Manufacturing Company in Bradford, PA, where he was responsible for management, sales, profit and forecasting functions for all US customer accounts.

“Falcon’s strong reputation as a leading manufacturer in their industry drew me to exploring this opportunity,” said Smith. “The ability to further my career while leveraging my professional experience and relationships in consumer products manufacturing was exactly the next step that I was looking to take. I’m looking forward to working with my new team and helping Falcon Safety Products solidify and enhance its position as the leading manufacturer in the industry.”

Smith holds a Bachelor of Science in History Education and Social Science from Bradley University. He currently resides in Budd Lake, NJ with his wife and four children.

About Falcon Safety Products Inc.

Founded in 1953, Falcon Safety Products Inc. is a privately held corporation headquartered in Branchburg, New Jersey. A world leader in compressed-gas technology, Falcon manufactures a diverse line of products including the Dust‑Off® brand of computer / personal electronics cleaning products and signal horns for the marine, sport and safety markets. For additional information, please contact Falcon Safety Products Inc. at 908‑707‑4900 or visit www.falconsafety.com.

Check out this cool video from from The Aerosol Manufacturer’s Association (South Africa). It uses real school kids to get the message out about Aerosol Recycling. Here are the lyrics, feel free to sing along…and pass it on!

Now here’s the thing that you should understand
The bigger picture with an aerosol can
In daily life it plays a pivotal part
Let’s check the process, we’ll take it from the start

Inside the can is a gas called propellant
You press the nozzle down, product comes out
Do you feel it?
Do you feel it?

Long time ago there used to be CFCs
But we found out that it was bad for the environment
So Aerosols aint got no CFCs
I said, Aerosol aint got no CFC

Now here’s a fact that you can be proud of
Material that the cans are made of
Can be recycled, and this is great
We’re talking ’bout
Aluminium and tin plate

Chorus x 3

Don’t do things that you know are bad
Make sure you share this with your mom and dad
Don’t pierce, don’t squash, don’t burn the can
Get rid of it the right way and make a stand

Before you throw the cans away make sure that they are empty
Your life is not a game
Your life is not to play with

Reduce, reuse, Recycle today
Let’s keep the earth a beautiful place
Everybody needs to play their part
So let’s all take this message to heart

Every year we use millions of cans
That’s why recycling is part of the plan
Now take a moment let the thought sink in….

Ha, ha!

Chorus x 3

]]>http://www.spraytm.com/check-out-the-fun-recycling-video-from-south-african-aerosol-manufacturers-association.html/feed0Colep acquires contract manufacturing plant in Mexicohttp://www.spraytm.com/colep-acquires-contract-manufacturing-plant-in-mexico.html
http://www.spraytm.com/colep-acquires-contract-manufacturing-plant-in-mexico.html#commentsWed, 06 Nov 2013 19:49:19 +0000http://www.spraytm.com/?p=5056Colep, a leading global player in the consumer goods packaging and contract manufacturing industries, has announced today the acquisition of the aerosol personal care products contract manufacturing plant of Aerosoles y Liquidos S.A de C.V., in Santiago de Querétaro, Mexico. The new company will trade as Colep S.A de C.V.

With this acquisition, Colep initiates its operations in the Central and North American contract manufacturing markets for personal care products. From this manufacturing base, the company will serve its already existing blue chip customer base, as well as other important multinational, regional and local brand owners.

This plant will now be added to Colep’s network of 10 contract manufacturing plants in Europe and Brazil, where it manufactures a wide variety of aerosol, liquid and cream products. The company will make additional investments in this plant to increase production capacity and further enhance its manufacturing standards, thus creating an offer of comparable quality to the highest international requirements.

This acquisition follows the announcement made by the company on the 12th September 2013, of a global supply network with the One Asia organisation, covering the whole of their respective organisations in Australia, Japan, China, Thailand, India, Poland, Germany, Spain, Portugal and Brazil.

With this new addition to its manufacturing footprint, Colep moves one step further in developing its strategy of becoming a truly global partner for consumer goods companies, supporting the implementation of their projects on a global basis.

In the U.S., the hair care product market grew 3% in 2012, similar to 2011, according to Euromonitor International. Relatively high growth rates for standard shampoos and conditioners were offset by single-digit growth in styling agents and value decline in hair colorants, 2-in-1 products, and perms and relaxants.

Globally, the world hair care market in 2007-2011 also witnessed 3% growth, and in 2011, the total revenues of the market stood at over $50.342 billion. Over the same period of time, consumption volumes grew at a 3.8% rate and in 2011 exceeded 14.466 billion units, according to Haircare: Global Industry Guide, drawn up by MarketLine and published by Market Publishers Ltd.

A Matter of Style

The hair styling product manufacturing industry experienced a rocky past five years. Consumers’ disposable income fell during the U.S. recession, discouraging them from spending on hair care products, explains Hair Styling Product Manufacturing in the US: Market Research Report from IBISWorld. Looking forward, demand is beginning to return, and export markets in emerging economies are growing even faster.

One sign things are picking up is the fact that there has been no shortage in the launch of hair styling products this year. For example, Superdrug drug store chain launched its own extensive collection of hair care products called THIS ONE. The range includes a Blow Dry Spray, Replenishing Treatment, Curl & Wave Crème, Hair Oil, Shampoos and Conditioners. All products carry the Cruelty Free International symbol and come in packaging supplied by M&H Plastics.

New from Kao, Inc. is KMS California Hair Play, a playable texture spray that builds texture with additional applications so consumers can re-work a style at any time. The multi-functional product leaves hair feeling natural, not sticky, and is suitable for prepping, styling and finishing. It sports the Moritz Twist-To-Lock accessory from Aptar Beauty + Home.

Sexy Hair Concepts Texturizing Spray Clay Shine: 1 Hold: 7 is a non-traditional clay in a spray form. The 4.4oz and 1.4oz. aerosol applications allow for fine and even product distribution to achieve an all-over textured look with a matte finish and a dry, non-waxy hold. Sexy Hair Concepts Play Dirty Dry Wax Spray Shine: 4 Hold: 4 provides dimension and a semi-shine for a chic, “second day” look. Cans for both come from Condensa.

Jheri Redding Ultra Holding Hairspray from Conair provides a long-lasting hold for all hair types. Suitable as a working spray or finishing spray, it is humidity-resistant, fast drying and natural looking. It comes in a can from DS Containers.

One ‘n Only Speed Style hair care products are specifically designed to help repel moisture, resulting in reduced drying time and less thermal stress. Wet or dry, hair can be healthy-looking, smooth and shiny, full of vibrancy and body. The cans are from Exal.

Elnett Satin Hairspray Styling Heat Spray Curls’ advanced formula shields hair from high temperatures and is suitable for use with straighteners, curlers or a hair dryer. Enriched with humidity protectors, it helps keep hair looking full for up to three days. The 170mL outer container is injection molded in PET by RPC Bramlage. The inner bottle is manufactured in PP and extrusion blow molded by RPC Kutenholz to a special design created by L’Oréal. Both pieces are assembled at RPC Bramlage.

New Image Hypo-Allergenic Hold Hair Spray, from New Image Professional Products, Inc., was formulated without fragrances, lanolin, oils and lacquers. It has a firm hold to keep style in place all day, is water-soluble and crystal clear. It doesn’t turn gray hair yellow and is recommended for color-treated hair. It comes in a can from DS Containers.

Alterna’s popular smoothing Kendi Dry Oil Mist is now available as a Micromist to control frizz and impart shine on even the finest hair. Providing an ultra-lightweight, satin finish for frizzy hair, it helps tame flyaways and strengthens hair with eco-certified bamboo and other vital nutrients. It absorbs instantly for immediate results and protects color. The can is from Condensa.

Aloxxi’s Flexible Hairspray is an anti-humidity working hairspray that provides long-lasting, flexible hold while delivering a light shine and protecting hair color from UV damage. Also in the collection is the new Aloxxi Essential 7 Restorative Hair Serum that combines the power of seven botanic oils in a paraben-free formula that transforms the hair into silky-smooth, healthier-looking locks. Key ingredients include Olive, Walnut, Grapeseed, Clary Sage, Geranium, Sunflower and Jojoba Oils.

Dudley’s Oil Sheen Spray from Dudley Beauty Corp. can be used on all types of hair, wigs and hairpieces, and can be used as a glossifier and conditioner for pressed hair, relaxed hair, permanents and curls. It adds luster and sheen and is formulated to go on dry and firmly hold, yet leaves the hair with a soft, natural look. Packaging was provided by DS Containers.

Salon Inspired

Salon inspired products that mimic offerings sold in salons are increasingly popular in mass-market channels in the U.S., as consumers consider them to be of a higher quality than standard mass products.

Along these lines, Alberto VO5 launched Salon Series, an all-new line of styling and treatment products, shampoos and conditioners that create salon-quality results. Formulated from 11 natural oils derived from honey, papaya, kiwi, marigold and sweet almond, Salon Series products penetrate hair from roots-to-ends to create enhanced results, working in tandem with VO5’s proprietary, five-vitamin formula (E, H, C, B3 and B5). The line includes VO5 Salon Series Perfect Hold aerosol and non-aerosol hairspray, mousse and sculpting gel; Total Recovery Deep Conditioning Hair Mask; Anti-Frizz & Shine Styling Cream; and four each of new shampoos and conditioners.

BaBylissPRO MiraCurl hair care was developed to help enable professional stylists to achieve the best, longest-lasting results from the MiraCurl Professional Curl Machine or any automatic curling device. In addition, they are suitable companion products for use with traditional thermal styling tools such as curling, flat or specialty irons. The cans are from Exal.

Dry Shampoo Still on the Rise

A shower is no longer necessary when it’s time to suds up your hair. In fact, Mintel’s Global New Products Database found that in 2008, dry shampoo introductions accounted for just 1% of global shampoo launch activity, but by 2012 the segment captured 3% of the shampoo category and 2013 is on track to surpass 2012 levels.

Although availability of dry shampoos is widely accessible, consumer uptake remains relatively low. Only 16% of U.S. adults reported some usage of a dry shampoo in the last year. Across the Big Five European markets (UK, Spain, France, Germany and Italy), usage is relatively similar to that of the U.S., but peaks in the UK, where nearly a quarter (23%) of women are engaged in the segment.

Convenience is a compelling attribute for consumers and plays a definitive part in hair care product purchases. Nearly one in five (17%) women in the UK use dry shampoo when they don’t have time to wash their hair, and although this sentiment is less widely shared among the remaining Big Five European countries (only 5% of women), it identifies an important consideration for manufacturers.

Beauty enhancing claims are becoming more commonplace in dry shampoo development and have been present in 19% of global introductions since 2009. Brightening and illuminating benefits have posted the most significant growth, with introductions more than doubling (220%) between 2009 and 2011.

Bosley Professional Strength offers dry shampoo enhancements for consumers with fine and thinning hair. BosRenew Volumizing Dry Shampoo is specially formulated for fine to medium hair, and includes DHT inhibitors, which may help maintain healthy hair and scalp, while creating touchable volume for a thicker, fuller-looking style. The product’s formula not only absorbs dirt, excess oil and product build-up, but also helps extend the length of hair color by extending the time between washes. The multi-tasking dry shampoo provides advanced UV protection to defend hair against photo-aging and may help to stimulate the metabolic function of cells.

New York Streets (NYS) is designed for edgy, artistic individuals with a unique sense of style, explained the company. NYS Dry Shampoo was formulated to refresh hair, build volume and remove product build-up, as well as absorb excess oils and unwanted odors. Other new products in the line include Volume Foam for curly or fine hair without frizz; Xtreme Gel for super-hard spiking or slicking; leave-in hair strengthener.

Hair care’s bright future

Hair care in the U.S. is projected to see retail value growth of 12% to $11.9 billion in 2017, according to Euromonitor International. Thanks in part to a slowly improving economy in the U.S., consumers have proven their willingness to pay for premium and value-added products. Unit prices should only increase over that time as people with larger disposable incomes feel more comfortable trading up within the hair care category.

Globally, the hair care market is predicted to record growth of more than 3.3% during 2013-2016. By December, 2016, the market value is forecast to grow beyond $59.575 billion, according to MarketLine. SPRAY

There is often push-back on the need for corrosion testing, particularly when market timetables are short.

The no-corrosion-data risk is approximately 62% that some type of corrosion will occur in traditional aerosol containers. In other words, there’s only a 38% probability that corrosion will not occur in traditional aerosol containers. A similar risk has not yet been developed for spray packages with internal laminated aluminum foil bags.

The complexity of corrosion makes it impractical to use first principles to predict a) if corrosion will occur, b) how fast corrosion will degrade packaging materials and c) the package service lifetime. Consequently, corrosion testing is necessary to reduce the risk from approximately 62% to a more acceptable level of risk, such as 5% to 10%.

Let’s review the most common factors that make spray package corrosion complicated and thus make corrosion testing necessary to reduce the corrosion-risk to an acceptable level.

Microenvironments inside spray packages
Spray packages have numerous microenvironments formed by the internal geometry of the package and the physical form of the formula inside the spray package. The internal geometry of the package includes the open area inside the package plus seams formed when the container body is joined with the container top, bottom and valve. Tinplated steel aerosol containers and containers with laminated bags both have internal welds.
Gas-propellant formulas typically have at least a product phase (liquid phase) and a gas phase. Liquefied-propellant formulas typically have the liquid phase, the propellant phase and the gas phase. Formulas inside laminated bags typically have a single phase. Emulsion formulas could also have a product area with multiple cream phases.

Different types of corrosion
There are two major categories of corrosion referred to as general and localized corrosion. General corrosion typically does not affect package service lifetime, but could degrade product efficacy.

Localized corrosion is confined to small areas, typically on the order of microns to several millimeters. Localized corrosion is faster than general corrosion and typically reduces service lifetime by causing leaking of product or propellant.

Both general and localized corrosion could occur in any microenvironment inside the container. The corrosion in the different container microenvironments:

Requires different conditions to initiate general and pitting corrosion

Requires different conditions to sustain corrosion after initiation

Has different penetration rates and growth rates

Very small changes can significantly alter corrosivity
Typically only parts per million of corrosive ingredients are needed to initiate and sustain corrosion. However, there are some instances were only a few parts per billion of a contaminant is needed to initiate and sustain metal corrosion.

Corrosivity is often a function of concentration
The occurrence of corrosion and corrosion rates are often determined and influenced by concentrations of formula ingredients. Some of the more common concentration-factors are:

Ph (hydrogen ion concentration)

Concentration of formula ingredients

Concentration of contaminant water

Concentration of a corrosion inhibitor

Variability in manufacturing processes could alter corrosivity or corrosion resistance

Variability of your formula compositions and the materials used for your spray packages always occurs. Some of the more common sources of formula and package variability are:

Formula ingredient concentrations

Sporadic contamination

Laminate film and internal coating variability

Container and valve metal chemical composition variability (rare)

Sporadic physical defects in container and valves (rare)

Different metals have significantly different corrosion resistances with the same environment

Spray package metals could be tinplated steel, tin-free steel and aluminum. The number of polymer materials for spray packages is larger and many of these package materials are changing to address environment and regulatory issues.

None of these materials is corrosion resistant to all types of spray formulas. For example, aluminum generally is more corrosion resistant to corrosion by low pH formulas than steel. The opposite is generally true for high pH formulas.

In summary, spray package corrosion complexity is caused by a large number of factors and makes it difficult to predict a) if corrosion will occur, b) where corrosion will occur and c) how fast corrosion penetrates the package metals and grows through a laminate film or internal coating.

Consequently, corrosion testing is needed to determine when corrosion will be an issue for a given spray package-formula system. SPRAY

Please send your questions/comments/suggestions to rustdr@pairodocspro.com. Back issues of Corrosion Corner are available on CD from ST&M. Thanks for your interest and I’ll see you in December.

I began my career as a Dangerous Goods Consultant more than 20 years ago when I was working at the U.S. Coast Guard’s Marine Safety Office in Los Angeles-Long Beach, CA. I was the Division Chief for the Port Safety & Security and Container Inspection Divisions.
Although I enjoyed my job immensely and working with the fine young men and women of the U.S. Coast Guard even more, I found it very difficult and time consuming to process hundreds of civil penalty actions against those that violated the U.S. Dept. of Transportation’s (DOT) Hazardous Materials Regulations (HMR) in one form or another.
Although there were certainly a number of law-breakers that deserved to have the hammer dropped on them, most were one-time offenders that committed some rather benign error or omission. Because there was a “zero tolerance” policy in effect, our warnings were given in the form of civil penalty actions that ranged in price from a few hundred dollars to several tens of thousands of dollars.

I wondered what the solution might be—and then it dawned on me! We (the U.S. Coast Guard) should train the shippers, forwarders and steamship lines on how to comply with the regulatory requirements.

I put together a manual and invited 650 people to attend the “almost-free” training course at a local hotel. To my surprise, we had more than 600 positive responses, but sadly, had to close the door at 375 because we were exceeding the maximum occupancy for the ballroom. The training went well and it launched a rather exciting and lucrative career for me.

Now that I look back on it, I think compliance is really rather easy. It’s as simple as A-B-C. A few letters of the alphabet, when stringed together into simple mnemonics, can help the shipper and carrier understand some of the most complex regulatory requirements. A mnemonic is

“…any learning technique that aids information retention. Mnemonics aim to translate information into a form that the human brain can retain better than its original form. Even the process of merely learning this conversion might already aid in the transfer of information to long-term memory…Their use is based on the observation that the human mind more easily remembers spatial, personal, surprising, physical, … humorous, or otherwise ‘relatable’ information, rather than more abstract or impersonal forms of information.”

For example, one of the more common violations of the HMR is the incorrect basic description sequence. Prior to 2012, the basic description sequence on hazardous materials shipping papers was: (a) proper shipping name, including correct technical or chemical names, if they applied; (b) hazard class, division and compatibility group; (c) identification number; and (d) packing group, if applicable. I had created a simple acronym to help my students remember the basic description sequence: S-H-I-P, which represented the: (a) Shipping name; (b) Hazard class, division and compatibility group; (c) Identification number, preceded by the letters “UN” or “NA” as appropriate; and (d) Packing Group, if it applied.

All was good until the U.S. DOT changed the requirements to reflect the international system of dangerous goods documentation, which requires the identification number to be listed first. Knowing that I-S-H-P is not a word, I changed the mnemonic to I SHIP. I ship hazardous materials all the time—I ship them on a boat, train, truck and plane. I S-H-I-P: Identification number, Shipping name, Hazardous class Including the division and compatibility group, and Packing group, if it applies.

By creating simple acronyms and memory aids, my students are able to recall the most important requirements with the HMR.

A few more that you might find helpful:
When trying to remember the required information on a hazardous materials shipping paper, remember the acronym:

SHIPMATE

S Shipping name including the correct technical and chemical names, if applicableH Hazard class, division and compatibility group, if applicableI Identification number, preceded with the letters UN, NA or ID as appropriateP Packing groupM Mass (weight) and VolumeA Additional descriptive information (such as permits and approvals, flashpoint)T Telephone number in the event of an emergency E Emergency response information that addresses six emergency situations

The emergency response information is required to be provided on a hazardous materials shipping paper using one of the three methods, as follows:WAXW Written on the dangerous goods declaration A Attached as separate document (such as a Safety Data Sheet)XX-referenced to a third, but available document (e.g., an Emergency Response Guide)

When involved in or responding to a hazardous materials spill or release, remember this important word:GING Get away; I Isolate (or Identify), andN Notify others

By using these simple learning tools, one can develop a deeper, better understanding of the regulatory requirements and, maybe, just maybe, have a little fun while doing it. SPRAY

On Sept 26, 2013 The California Air Resources Board (CARB) held an Executive Board hearing to adopt amendments to the Consumer Products regulation and to the Aerosol Coating Products regulation. The formation of these amendments has been in development for over two years. Some of the highlights for the Consumer Products regulation are the following:

• HFO-1234ze was added to the list of exempt volatile organic compounds (VOC) compounds in

the state of California for Consumer Products.

• There were changes to several lubricant definitions that clarify the categorization of several

• There was an addition of Single Purpose Cleaner and Degreaser definitions. The addition of these two definitions clarifies the use of products that are used for a single purpose and are not general-purpose products.

• The delay of the 10% VOC limit for Multi-purpose Lubricant from 12/31/2015 to 12/31/2018 will provide industry time to meet this stringent future effective limit.

• Changes to the Hair Spray definition should clarify the issues for this category.

• New Spray Adhesive limits will be very difficult to meet. Industry will have a challenge to meet these limits.

• Likewise, the new Multi-purpose Solvent and Paint Thinner limits in the South Coast Air

Quality Management District (SCAQMD) will be very challenging. Product efficiency will likely be degreased.

• Remember, there are new VOC limits for Aerosol Multi-purpose Solvents and Aerosol Paint Thinners.

For the Aerosol Coating Product Regulations there are too many changes to highlight. If you make Aerosol Coatings, I highly recommend that you review this regulation closely:

• The biggest change is that all products meeting the definition of aerosol coatings are regulated by this regulation unless specifically exempted. This means review product labels closely and make sure claims represent the appropriate category for your product.

• There are numerous changes and additions to definitions; please review to make sure you understand the changes.

• There are numerous changes to VOC limits; start reformulation of products now.

Industry is still working with CARB on the effective date of 2010 MIR values that will be used for the future effective limits. Remember, some limits are effective 1/1/2015 and others are effective 1/1/2017. Now that the board has approved these amendments, CARB can begin to prepare for finalization of these amendments. The amendments need to be submitted to the Office of Administration Law (OAL) before the amendments become final. In the meantime, CARB will continue working on new issues. Industry will need to closely monitor the low vapor pressure (LVP) research work. In addition,CARB will be starting work on a new and comprehensive product survey, so stay tuned.

New Hamsphire began work in October to update their state rule with the new Ozone Transport Commission (OTC) model rule. As this rule progresses, we will keep you informed. OTC continues

to push the U.S. Environmental Protection Agency (EPA) into making this new OTC model rule a

national rule.

Green Chemistry

The Dept. of Toxic Substances Control (DTSC) Safer Consumer Products regulations took effect Oct. 1, 2013 and will be phased in over the next several years. The goals of this program are to reduce toxic chemicals in consumer products, create new business opportunities in the emerging safer consumer products economy, and reduce the burden on consumers and businesses struggling to identify what’s in the products they buy for their families and customers.

Timeframe for Implementation Milestones

Initial Candidate list: Effective date of the regulations

First “Proposed” Priority Products list: 180 days after the regulations effective date

First Priority Products list finalized: Requires rulemaking (may take up to one year)

Priority Product Notification: 60 days after listing on final Priority Products list

Preliminary Alternatives Analysis (AA) Report: due to DTSC 180 days after listing on final Priority Products list

Final AA Report: due to DTSC one year after the notice of compliance for the Preliminary AA Report

Regulatory Response Implementation: To be specified by DTSC in the regulatory response determination

Under the U.S.’ GHS-based Hazcom 2012 rule, employers are expected to train “employees on the new label elements and safety data sheet (SDS) format” by December 1, 2013. This training is to be given to all employees that would normally receive any OSHA training. Note there are additional training requirements in Hazcom 2012, but only the “new label elements and safety data sheet format” training requirements are subject to the December 1, 2013 deadline.

OSHA has a helpful document on the minimum requirements for the training elements required by December 1, 2013 available at: https://www.osha.gov/Publications/OSHA3642.pdf. Included are training on the label elements: product identifier, signal word, pictograms, hazard statements, precautionary statements, company contact info. Employers are required to explain how an employee might use the labels in the workplace, general understanding of how the elements work together on a label, how the information on the label is related to the SDS as well as the information located in each of the 16 sections of the SDS.

We have been recommending to our client that they are vigilant in recording the date and method for each employee that was trained. Furthermore, we recommend (though it is not a firm requirement) that any employee receiving training is given a written test on what they have learned, as it is a requirement that training be given in “a language and vocabulary that employees can understand.”

]]>http://www.spraytm.com/reminder-the-dec-1-2013-hazcom-2012-training-deadline-is-approaching.html/feed0WAIB October Legislative Update:http://www.spraytm.com/waib-october-legislative-update.html
http://www.spraytm.com/waib-october-legislative-update.html#commentsTue, 22 Oct 2013 17:19:54 +0000http://www.spraytm.com/?p=4921CanadaOn September 16, 2013 Environment Canada (EC) issued a proposal to add 13 compounds to the VOC Exclusion list under Schedule 1 of CEPA. A 30 day comment period commenced. Some of the compounds include TBAC, DMC, HFO-1234ZE, and HFO-1234YF. Comments were submitted by CPCA in support of the proposal.

CaliforniaCalifornia Air Resources Board (CARB)- On September 26, the California Air Resources Board (CARB) voted unanimously (with one recusal) to support the resolution on the Proposed Aerosol Coating Products and Consumer Products Regulations. Staff proposed a subsequent 15-day public comment period to address technical issues related to the clarification of VOC limits for multipurpose solvents and paint thinners in the South Coast Air Quality Management District (SCAQMD) and a drafting error in the Method 310 language.
It is expected the Air Quality Planning and Science Division staff will prepare andrelease the proposed technical changes for a 15-day public comment period prior to the end of the year.

Department of Toxic Substance Control (DTSC) -Green Chemistry – On October 1st the DTSC announced the launch of its Safer Consumer Products (SCP) program. DTSC published informational lists of candidate chemicals on the new Safer Consumer Products Web site. The purpose of these informational lists is to inform stakeholders about chemicals that may be named as Chemicals of Concern if they are later identified by DTSC as part of a product-chemical combination that is listed as a Priority Product. DTSC expects to identify up to five priority products by April of 2014. Makers of those products will be expected to march through the onerous requirements of the SCP program.

South Coast Air Quality Management District (SCAQMD) - Rule 1168 Adhesives and Sealants – On September 19th, SCAQMD held their 3rd work group meeting on proposed amendments to Rule 1168. As usual with the SCAQMD, they are attempting to extend their authority to include products already regulated by CARB. In this rule, they are attempting to bring in Aerosol Adhesives and consumer adhesive products used in manufacturing processes. Even though SCAQMD has admitted the VOC reductions from this rule will be minimal they intend to proceed. There are categories of overlap with other rules and definitional issues they intend to clarify during the rule making along with lowering limits wherever possible.

New HampshireThe New Hampshire Department of Environmental Services(DES) issued its initial proposal to readopt and amend the consumer products regulation (Env-A 4100). New Hampshire Rulemaking Register (Sept. 19, 2013).The DES held a public hearing on Thursday, October 17, in Concord, NH. Written comments must be filed on or before 4:00 p.m. on October 24.

LIQUID WRENCH to lower VOC Levels for aerosol products in 2014

The LIQUID WRENCH brand announced plans to reformulate their aerosol lubricants in accordance with 2014 Volatile Organic Compound (VOC) regulations. This decision serves as yet another example of the commitment to developing advanced product formulations that are high-performing, yet safer for consumers and more sustainable for the environment.

The LIQUID WRENCH brand continues finding innovative ways to enhance the performance of their products. In 2010, LIQUID WRENCH Penetrating Oil was reformulated to less than 1% VOC. In addition, the LIQUID WRENCH brand now adds Cerflon®, ceramically-reinforced PTFE, to their lubricants for superior lubricity and better wear protection. More recently, parent company RSC purchased a majority stake in Terresolve Technologies, a leading manufacturer of biobased hydraulic functional fluids and lubricants, which is now operating as RSC Bio Solutions.

With today’s announcement, the LIQUID WRENCH brand plans to reformulate their products to meet the new 2014 California VOC regulations, which limit penetrants, multi-purpose lubricants, chain lubricants, rust preventative and rust control lubricants to a maximum of 25% VOC. As well, the brand is committed to reducing VOC levels for all their aerosol products to 0% by 2016.

While the costs associated with reformulating products to meet the new VOC standards are expected to impact retail prices, the LIQUID WRENCH brand will continue to provide consumers with the most effective and safest lubricant products on retailer shelves.

“All brands in this space, including our competitors, will be required to adhere to more stringent VOC standards,” said Chris Ott, Brand Manager of LIQUID WRENCH. “As a champion for the ambitions of fixers, makers, and innovators across the country, we want to lead by example. We are opting to reformulate our products, sold nationwide, to meet the California VOC standards sooner rather than later. Offering an exceptional product while being mindful of the safety of our customers and our impact on the environment has always been, and will continue to be, a core tenet of the RSC brand family.”

]]>http://www.spraytm.com/liquid-wrench-to-lower-voc-levels-for-aerosol-products-in-2014.html/feed0Fitzgerald joins Cobra Plastics’ Aerosol Divisionhttp://www.spraytm.com/fitzgerald-joins-cobra-plastics-aerosol-division.html
http://www.spraytm.com/fitzgerald-joins-cobra-plastics-aerosol-division.html#commentsMon, 14 Oct 2013 17:32:48 +0000http://www.spraytm.com/?p=4900Cobra Plastics Inc. has announced that Sean Fitzgerald has joined the company as Director of Sales, Aerosol Division. Fitzgerald’s sales career in the aerosol business has spanned the last 24 years and has covered valves, fragrances, cans (tinplate and aluminum), contract filling and propellants. He has been active in industry organizations such as the CSPA Board of Directors, CSPA Aerosol Board, NAA President, member of the SATA Board of Directors, as well as member of both the EAA and WAIB.
]]>http://www.spraytm.com/fitzgerald-joins-cobra-plastics-aerosol-division.html/feed0Holiday sales increase cautiouslyhttp://www.spraytm.com/holiday-sales-increase-cautiously.html
http://www.spraytm.com/holiday-sales-increase-cautiously.html#commentsTue, 01 Oct 2013 14:24:17 +0000http://www.spraytm.com/?p=4771Solid consumer spending in the month of December helped retailers finish 2012 with a healthy holiday shopping season, according to retail trade association The National Retail Federation (NRF). December 2012 retail sales excluding automobiles, gas stations and restaurants) increased
2.1% year-over-year. Ultimately, total holiday retail sales increased to $579.8 billion, while non-store holiday sales grew 11.1%.

Also for guest or home use is Philosophy Holiday Hands, a set designed to stay close to the sink to give hands a treat. The hand wash gel and hand lotion crème come in a Cranberry Currant fragrance and are color coordinated in holiday red. Both sets of products feature the Euroflow pump from Aptar Beauty + Home.

Perfect for entertaining is Liquor Whipped premium vodka-infused whipped cream in White Chocolate Peppermint. The Temperance Distilling Co. delicately blends the flavors of natural chocolate and peppermint with the light creamy texture of decadent whipped cream; it then infuses the perfect amount of premium vodka for that extra little kick to top off drinks or desserts. Liquor Whipped comes in a festive, holiday-themed can from DS Containers that sports a valve from Clayton Corp.

Love is in the air

And in the malls. A 2013 Valentine’s Day spending survey conducted by BIGinsight indicated the average U.S. consumer spent approximately $130.97 on gifts, candy and cards, up from $126.03 in 2012; total spending was approximated at $18.6 billion.

“Valentine’s Day remains one of the biggest gift-giving holidays of the year, and although consumers will be conscientious with their spending, it’s great to see that millions of them are still looking forward to celebrating with their loved ones,” said NRF President & CEO Matthew Shay. “Recognizing their customers will shop for both price and value, retailers…will offer plenty of promotions for anyone looking to spoil those that mean the most to them this February 14th.”

Victoria’s Secret has a bevy of new products to be given and/or worn on Valentine’s Day. PINK So Fresh Body Lotion has a light scent of vanilla orchid and airy musk, and packs an instant moisture infusion of aloe, oat and grapeseed extracts, as well as vitamins E and C. PINK So Fresh 2-IN-1 Shower & Shave Wash is a double-duty foaming mousse, creating a fluffy lather for gentle cleansing and smooth shaving. Nourishing jojoba oil and aloe vera leaves skin smooth and soft. Both products are wrapped with VS’s iconic shocking pink label and embellished with a holographic heart. Victoria’s Secret Fantasies limited-edition Sugared Florals collection includes a body mist scented with a blend of sugared lilac and praline, and infused with conditioning aloe vera. All three products feature packaging from Aptar.

Fall fragrance launches–for him

Sales of U.S. prestige men’s fragrance increased 6%, to $953 million, from May 2012–April 2013, according to global market research firm The NPD Group’s 2013 Men’s FragranceTrack study. In that time period, 25% of U.S. male consumers purchased a pre-packaged gift set as a result of the perceived value, and the ancillaries included in the set. Larger fragrance sizes presented a value benefit as well. Unit sales of men’s fragrance, in sizes 6.7oz and up, increased 12% from May 2012–April 2013 compared to the previous year. These larger sizes represented more than 6% of dollar sales during the same timeframe.

“Men, and those who purchase fragrance for them, are spending 4% more on fragrances than they did a year ago,” explained Karen Grant, NPD Group VP & Senior Global Industry Analyst. “With a quarter of adult men who wear fragrance saying that they never purchase it for themselves, fragrance becomes the perfect, low stress gift for the man in your life. His scent selections don’t vary much, his requirements are generally basic, and if you like it, it is almost certain he will like it,” she concluded.

Jean-Paul Gaultier launched the Limited Edition 2013 Le Mâle by Jean-Paul Gaultier. The 75ml EDT has notes of lavender, mint and vanilla. It comes in a bottle from Pochet du Courval, featuring the iconic striped jersey (image, lower left), this time with a bright red heart tattoo on the chest, suitable for Christmas or Valentine’s Day gift giving.

Fragrance launches–for her

Prestige women’s fragrance dollar sales increased 8% while units were up 3%, and the average price was up 5% in the first quarter of 2013, compared to the same time period last year, according to The NPD Group.

“Women are spending more on their fragrances than last year, treating themselves to something a little more special,” said Grant. “Higher price points are driving the growth in sales.”

Women’s fragrances priced $100-and-up grew almost 40% in sales, account for 22% of dollar sales and have surpassed the sales of women’s fragrance gift sets under $100 (20% of dollars). Despite this, gift sets gained 9% in sales in the first quarter of 2013 compared to the same time period last year. 2013 Rank

Eau de parfum (EDP) options represent 62% of the market, and showed gains, but it was colognes, with a 4% share of women’s fragrance, that displayed a significant double-digit increase in dollars. Within women’s cologne, the growth was driven by niche brands, which accounted for 90% of the segment’s dollar sales in the first three months of 2013.

“Colognes offer women lighter concentrations and allow them to get the scent they desire without feeling overwhelmed,” said Grant.

Floral fragrances represented more than a third of women’s fragrance sales between January and March 2013, with the top growing fragrance families—water, oriental and citrus— representing just over 5% of women’s fragrance sales.

Prestige women’s fragrance dollar sales increased 8% while units were up 3%, and the average price was up 5% in the first quarter of 2013, compared to the same time period last year, said NPD.

Just in time for the fall and holiday seasons, iconic fragrance brand Lolita Lempicka delivers a new scent that radiates femininity and love—Elle L’aime. The scent marks Lolita Lempicka’s biggest U.S. launch in over a decade. Elle L’aime (which translates to “She Loves”) is comprised of top notes of bergamot, neroli and lime; mid notes of coco essence, jasmine and ylang-ylang; and base notes of vanilla, myrrh and sandalwood. The scent was created by Christine Nagel and Serge Majoullier of French fragrance house Mane and is housed in a bottle representing a golden totem pole.

Chicago-based boutique fragrance development company Tru Fragrance announced the second harvest of Tru Blooms, a first-of-its-kind initiative that originally debuted in 2012. This year’s project will transform even more of Chicago’s gardens and green spaces into growing spaces to cultivate flowers that will be harvested and bottled into a limited edition perfume.

Click image for full size

In 2012, Tru Blooms cultivated more than 22 green spaces throughout Chicago, provided specialized job training for more than 150 workers and created more than 60 jobs for local residents. This year, 27 green spaces are being planted across the city and Tru Blooms hopes to provide even more jobs and job training to local residents.

Tru Fragrance partnered with perfumer Stephanie Hakes of Ungerer & Co. to capture the essential oils and essence of the flowers to create the limited edition Tru Blooms Second Harvest Eau de Parfum, which will be available in two sizes—50ml and 15ml at select locations and online beginning in November. Pre-orders will begin online on October 14.

Click image for full size

Tru Fragrance also announced Honey as the HipNote for the fall season. A versatile scent that adapts attributes from its origins, honey can be woodsy, floral or herbal. HipNote Honey comes from the Acacia shrub, giving it a complex sweetness and delicate, floral aroma. It features top notes of delicate freesia, hedione and muguet, which evoke the feeling of a fresh fall breeze, blooming flowers and a vision of bees working effortlessly in a scenic garden. The scent was crafted by perfumer Pierre Negrin of Firmenich. SPRAY

]]>http://www.spraytm.com/holiday-sales-increase-cautiously.html/feed0Knock, knock…We’re with the government… we’re here to help!http://www.spraytm.com/4865.html
http://www.spraytm.com/4865.html#commentsTue, 01 Oct 2013 04:01:58 +0000http://www.spraytm.com/?p=4865Many years ago I had developed a written procedure titled Receiving Government Inspectors. This was in response to an isolated incident whereby the client had badly mishandled the inspector’s visit by refusing a lawful inspection and insisting on a search warrant. As a result, the client received a very large civil penalty (more than $850,000), even though there were very few, if any, minor infractions of the Hazardous Materials Regulations.

Later that year, I had to rely upon the same procedure when I suddenly received a Federal Aviation Administration inspector at my home! At the time, I was working from my home, having been in business for only a couple of years. Obviously, I was nervous when the agent flashed his badge and demanded entry. The inspector insisted on seeing our “…chemical storage facility, shipping docks, warehouse and offices,” so I invited him in and promptly showed him my kitchen pantry, driveway, garage, and dining room table. Satisfied, he left, scratching his head on the way out.

Immediate Actions

Before any regulatory agency inspection, companies should develop, implement and provide training on a procedure to deal with visits from federal, state or provincial, or local regulatory agencies. These include, but are not limited to, routine and non-routine visits from the Dept. of Transportation (DOT) (or its modal enforcement agencies), federal or state occupational safety and health administrations, environmental protection agencies, customs and border protection, health departments, fire marshals, solid waste management agencies, or even the local air quality or water quality management board.

When an inspector arrives at your facility, whether announced or unannounced, you should do the following:

Identify the Inspector

Ask to see his or her credentials, exchange business cards and write down the inspector’s name, agency, scope of the inspection and statutory authority they are inspecting under (e.g., 49 CFR subchapter C Hazardous Materials Regulations). In almost all cases, the inspector will offer a business card, show their badge and identification, and describe the scope of the inspection and why they have come to your facility.

Make Management Available

You should immediately notify facility management and make a corporate officer available to speak with the inspector. The corporate officer may delegate a person or persons to accompany the inspector or answer questions after an initial pre-brief meeting. I strongly recommend that the company designate one or more persons as “Compliance Managers” or “Facility Inspection Coordinators.” These persons should be trained in the proper protocol for receiving government visitors, prepare for agencies inspections, and be the initial “go-to guys” when the inspector arrives.

Determine the Scope

Ask the inspector to identify those activities of particular interest. By defining the scope of the inspection, this will limit what the inspector will see and will help you expedite the process. As indicated before, more often than not, the agency inspector will define the scope of the inspection (e.g., training records, shipping papers, chemical storage, etc.).

Advise Legal Counsel

Advise legal counsel of the inspection. However, the agency inspection should not be stalled pending discussions with counsel, unless the agency presents a search warrant, in which case you may want to have legal counsel present. You should discuss these procedures with internal or external legal counsel and incorporate their suggestions or requirements into your written procedures.

Accompany the Inspector

You should not leave an inspector unattended in a warehouse, shipping dock or offices. You should accompany the inspector to the precise area that he or she needs to see. Do not detour or offer to show the inspector areas outside of the scope of the inspection. However, inspectors may request to interview an employee without the presence of management. In such cases, the employee should be made available during business hours and asked if they want legal representation or another representative to be present during questioning.

Questions and Answers

Questions, if understood, should be answered truthfully and succinctly. Do not elaborate beyond the scope of the question. If there is something that your facility is doing above and beyond the minimum requirements, you may mention or explain it, provided it is relevant to the line of questioning. For example, if the DOT requires training every three years but your company provides training annually, that fact is worth mentioning as it will cast a positive light on your compliance program.

Photographs & Documents

Photographs and copies of documents may, and often are, taken by agents during the course of an inspection. I recommend that if the inspector takes a photo, you take the same photo from the same angle. You may ask the inspector to describe why he or she is taking the photograph. Be careful to ask what it is that they see and not question whether or not they should take the photograph. In some cases, the agent may be taking a photo for training purposes or to show a positive example of something that a company is doing correctly. Copies of documents taken by the inspector should be marked as “Confidential.”

When in Doubt

Answer all questions that you are familiar with. If you do not understand the question, or if the line of questioning is outside of your expertise, it is perfectly acceptable to refer to the appropriate person who is qualified to answer, or to say “I don’t know, but I will find the appropriate person that can answer that.” You may also ask the inspector to pose the questions in writing, addressed to corporate counsel or to the designated contact. The worst thing that you can do is to guess and tell the inspector what you think they want to hear—particularly if the topic is not in your skill set.

Prepare a Memo

Prepare a memo or narrative description of the visit as soon as the inspector leaves. Include all relevant details of the inspection, including a description of the areas reviewed, persons interviewed, as well as copies of documents produced or requested, etc.

Follow-up

After the inspection, you should confer with management and counsel, discuss the scope of the inspection and review the Facility Inspection Report that the agent should leave following the inspection. If any discrepancies were noted during the inspection, they should be corrected immediately and documented thoroughly.

Counsel should consider formulating a written response and defense in the event that an enforcement action (e.g., civil penalty case) is initiated, even though one may not be started for weeks or even months. In addition, facilities should review their corporate policies and compliance procedures and take appropriate steps to improve these programs.

Be Polite

Often a regulatory enforcement official will make a courtesy visit. In many cases, they will offer advice and counsel which should be accepted graciously. However, don’t be fooled—they are there to do a job. If that means initiating an enforcement action as a result of some infraction, they will carry out their responsibilities, even though they may be overly friendly and non-threatening. In most cases, the agent will be very professional and courteous. You should be the same. Try not to be defensiveness or controversial. If you disagree, or the agent is clearly wrong, make a written note of the finding or opinion and address it through management and counsel.

Oh, and by the way, the case I referred to at the beginning of this article was eventually dismissed by the agency. The client learned a very powerful lesson and took the appropriate steps to correct the few deficiencies and implement a solid compliance program which is now a model for all industries.

If you would like a copy of this procedure that I wrote some years ago, please contact:

]]>http://www.spraytm.com/4865.html/feed0Amendments to the Consumer Products Regulation and the Aerosol Coatings Regulationhttp://www.spraytm.com/amendments-to-the-consumer-products-regulation-and-the-aerosol-coatings-regulation.html
http://www.spraytm.com/amendments-to-the-consumer-products-regulation-and-the-aerosol-coatings-regulation.html#commentsTue, 01 Oct 2013 04:01:33 +0000http://www.spraytm.com/?p=4853CARB
The California Air Resources Board (CARB) amendments to the Consumer Products Regulation and the Aerosol Coatings Regulation are still the top priority for Industry. The board hearing was held Sept. 26, 2013. There are significant changes to both regulations, therefore Industry needed to closely review the documents for all changes. This is very tedious and in the review process, each change needs to be analyzed to determine how the change could affect the industry or our products. Many times, our review interpretation is not the same as, for instance, CARB enforcements’ interpretation.
Whether Industry supports the changes or not, it at least needs to understand the change for enforcement purposes. The changes to the Aerosol Coating regulations will spawn a new round of CARB enforcement actions when these amendments become effective. Remember, in the future, all aerosol coatings will be regulated under this rule. Therefore, if you market aerosol coatings, make sure that your label claims are in sync with your category code or you may be subject to an enforcement action. This is particularly important for Aerosol Specialty Coatings because these coatings have a significant higher Maximum Incremental Reactivity (MIR) limit. Enforcement will be reviewing these products to ensure that they do not have general claims. Bottom line: review your product labels carefully.
On the Consumer Products regulation, the Aerosol Adhesives limits will be very, very difficult to meet. Currently, there are three years to comply with the limits. Industry should begin now to evaluate reformulation options to ensure that these limits are technologically feasible. If the limits are not feasible, we need to approach CARB on this issue. Likewise, changes to the Multi-purpose Solvent and Paint Thinner category for the South Coast Air Quality Management District (SCAQMD) are difficult to meet. In addition, some further clarification is needed on a few issues surrounding these categories.
Industry was able to get some other issues clarified in the regulation. The Dry Lubricant definition clarified that Dry Lubricants are not considered as other lubricants. Likewise, the Single-use definitions for General Purpose Cleaner and General Purpose Degreaser clarify that not all cleaners and degreasers are General Purpose but are Specialty Cleaners. Industry comments at the Board hearing need to reflect these changes.

OTC updates
The Ozone Transportation Commission (OTC) had its last Stationary Source Committee hearing in Washington, DC on Sept. 12. Hopefully, from that meeting we can get an update on the states movements toward adopting the new Consumer Products Model Rule. More to come on that topic.

Green Chemistry
The Green Chemistry regulation in California—called the Safer Consumer Product Regulation—will become effective Oct. 1, 2013. However, only partially, as some sections were sent back out for comment. We will need to wait and see how this plays out. Nonetheless, the regulation will become effective in the future. Now we need to wait and see which products and which chemicals of concern are targeted by the agency.

EPA SNAP Meeting
On August 22, the U.S. Environmental Protection Agency (EPA) hosted a stakeholder meeting on the Significant New Alternative Policy (SNAP) program. The focus of the meeting was on President Obama’s Climate Action Plan. The plan is “to encourage private-sector investment in low-emissions technology by identifying and approving climate-friendly chemicals while prohibiting certain uses of the most harmful chemical alternatives.” The target appears to be HFC 134a and refrigeration. However, consumer aerosols were mentioned a couple of times. EPA plans to have more meetings on this issue and break the meetings up by sector, with refrigeration going first, followed by the other sectors such as foams, aerosols, etc. This is another issue to monitor to ensure our products are not unfairly treated. SPRAY

Crevice corrosion is a type of localized corrosion that occurs in the small gap between two pieces of overlapping metal. Crevice corrosion could be general corrosion, pitting corrosion or both.

Crevices can be found in several areas of traditional aerosol containers. These areas are where a) valves and valves attached to bags are crimped to an aerosol container and b) container tops and bottoms are seamed onto the body. Container welds do not typically form a crevice where the original edges are overlapped for welding because a complete weld is a single piece of metal.

Notice the top and bottom seam crevices have similar morphologies. The crevice area is also similar for a traditional valve crimp and a crimp between valves with attached bags.
What makes crevice corrosion different from other types of corrosion? The gap between the two pieces of metal form a microscopic capillary that initially draws liquid from your formula into the gap (crevice) via capillary action. The crevices at the top of a container and the valve crimp area are submerged under formula when the propellant is pumped into the container at high pressure, allowing capillary action to draw liquid into these two top (vapor area) crevices.
The liquid drawn into the crevice often has a chemical composition that is different from the chemical composition of your formula. Corrosion might start in the crevice after it is filled with liquid; depending on the a) chemical composition of the liquid, b) the type of container metal and c) the type of surface treatment on the container metal (e.g., coated or uncoated).
The fun begins after corrosion starts. Metal ions from corrosion diffuse into the crevice liquid, further changing the chemical composition of the liquid inside the crevice. Liquid from the container diffuses into the crevice in an attempt to dilute the crevice liquid.

However, electrochemically active ions and molecules in your formula can be reduced by electrons from the container metal, and electrons move through metal many times faster than liquid diffuses into the crevice.

Consequently, metal corrosion inside a corroding crevice is accelerated in an effort by nature to make the chemical composition of the liquid inside the crevice the same as the chemical composition outside the crevice. In other words, electrons from the metal inside the crevice are sent to metal outside the crevice in an effort to reduce electrochemically active ions and molecules in the formula outside the crevice area. This attempt to reduce electrochemically active ions and molecules is an effort to make the chemical composition of the liquid inside the crevice the same as the chemical composition of your formula outside the crevice.
Metal ions produced by corrosion draw water (or contaminant water) from your formula into the crevice to hydrolyze the metal ions. The corresponding hydrolysis reaction acts as a buffer that drives the pH of the crevice liquid to four. A pH of four is very corrosive toward the steel and the aluminum alloys used to fabricate aerosol containers.

The cycle of corrosion, diffusion of water into the crevice and buffering the crevice to a pH of four continues until the container is perforated. A portion of the hydrated metal ions in the crevice also diffuse out of the crevice and precipitate as hydroxides in the area around the crevice opening. These precipitates are the reddish-brown rust (with steel) and white (with aluminum) material that is present in the area next to a pit.

More info: www.pairodocspro.com. Please send questions/comments/suggestions to rustdr@pairodocspro.com. Back issues of Corrosion Corner are available on CD from ST&M. Thanks for your interest and I’ll see you in November.

]]>http://www.spraytm.com/what-is-crevice-corrosion.html/feed0Aerosol Association of Australia elects new Presidenthttp://www.spraytm.com/aerosol-association-of-australia-elects-new-president.html
http://www.spraytm.com/aerosol-association-of-australia-elects-new-president.html#commentsWed, 18 Sep 2013 13:44:01 +0000http://www.spraytm.com/?p=4763The Aerosol Association of Australia has elected John Bigley as its new President. Bigley is Managing Director – Metal Australasia for Ardagh Group, Australia’s largest manufacturer of tinplate and aluminum aerosol cans.

He joined the Aerosol Association of Australia’s Executive Committee in 2011 and has chaired the Association’s PR and Marketing Working Group since its inception in early 2012.

Bigley has worked in the packaging industry for 25 years, including serving as Manufacturing Director for the Specialities Division of Ardagh Metal in Europe and various regional roles with Metal Box, US Can and Impress.

He was also previously the Chairman of the British Aerosol Manufacturers’ Association and the (UK) Metal Packaging Manufacturers’ Association.

Commenting on his new role, John Bigley noted: “I am honored to be elected as President of an association which is recognized by its peers as pioneering many important industry initiatives ranging from promoting awareness of aerosol recyclability to its bi-annual industry awards which recognise innovation and excellence in the industry.”

“I am also keen to build upon my predecessor’s work in reviewing and expanding the range of services offered to Association members and ensuring that the Association takes a leadership role in important imperatives such as sustainability and product stewardship.”

Former Association President, Lindsay Showyin, will retain his Presidency of the Asian Aerosol Federation and chair its next meeting in Sydney, Australia in April 2014.

]]>http://www.spraytm.com/aerosol-association-of-australia-elects-new-president.html/feed0Lindal Group Appoints New Regional Sales Directors for North America and Germanyhttp://www.spraytm.com/lindal-group-appoints-new-regional-sales-directors-for-north-america-and-germany.html
http://www.spraytm.com/lindal-group-appoints-new-regional-sales-directors-for-north-america-and-germany.html#commentsTue, 17 Sep 2013 14:36:22 +0000http://www.spraytm.com/?p=4759The LINDAL Group —manufacturer of valves, actuators and spray caps for aerosol products—announced the appointment of two new sales directors for North America and Germany. Alex Piagnarelli was named Sales Director, North America, and Tony Harman was appointed Sales Director, Germany. Both report to Phil Lever, the company’s Group Sales Director.

According to Lever, Piagnarelli and Harman have extensive sales development and account management experience in industrial products. “We see exceptional opportunities ahead for Lindal aerosol solutions as the growth from our multinational customers increases,” Lever said. “Both Alex and Tony are skilled, experienced sales and business development professionals who have handled large international – and regional – customers. I am confident they will deliver on our sales plan and profitability targets.

“With our mix of multinational customers, and the pent-up demand for innovative aerosol packaging, the potential for significant gains is tremendous and we look forward to Alex and Tony’s addition to our team,” Lever said.

Alex Piagnarelli has more than 20 years of sales and account management experience in the Packaging industry. Most recently, he was Vice President Sales & New Business Development for Montebello Packaging, a leading maker of aluminum and laminate tubes, aerosol cans and other products in the personal care and pharmaceutical markets. Previously, he was U.S. Sales Manager for Taplast USA, the global manufacturer of innovative dispensing systems; Vice President Sales & Marketing for M&H Plastics; Vice President Sales & Marketing for Zeller Plastik Inc.; and Director of Global Marketing for SeaquisPerfect Dispensing. A graduate of Western Illinois University, Piagnarelli earned an MBA from DePaul University.

Tony Harman’s extensive career includes extensive experience in technical product sales and account management. Most recently, Harman was Sales Manager for Avery Dennison, a global leader in labeling and packaging materials. Previously, he was Sales & Marketing Director for AMC Pancke AG – Division Intercoat, the global labeling materials maker, a Key Account Manager for the office supply solutions company Ahrend Bürobedarf GmbH & Co. KG, and has held other industrial sales positions.

A UK national, Harman has lived and worked in Germany for the past 20 years. His education includes studies at Woolwich Technical Collge and Brooklands Technical College. He resides with his family in Hamburg, Germany.

]]>http://www.spraytm.com/lindal-group-appoints-new-regional-sales-directors-for-north-america-and-germany.html/feed0Colep and the One Asia Network form a “new ultimate Aerosol Global Supply Network”http://www.spraytm.com/colep-and-the-one-asia-network-form-a-new-ultimate-aerosol-global-supply-network.html
http://www.spraytm.com/colep-and-the-one-asia-network-form-a-new-ultimate-aerosol-global-supply-network.html#commentsMon, 16 Sep 2013 17:02:35 +0000http://www.spraytm.com/?p=4754Colep, with headquarters in Europe and the One Asia Network, an alliance of three companies (Daizo Corp. of Japan, with operations in Japan, Thailand and China, Pax Australia and Asian Aerosols of India), have announced the creation of a global supply network, through the establishment of a Manufacturing& Technology Agreement, which will cover the whole of their respective organizations and thereby provide supply coverage from Australia, Japan, China, Thailand, India, Poland, Germany, Spain, Portugal and Brazil.

“[This alliance has] materialized in a Manufacturing & Technology Agreement, under which the parties will work together in Innovation, Research & Development, Quality, Operations and Safety, with the aim of delivering superior, faster and streamlined global solutions to our customers,” commented Vitor Neves, CEO of Colep.

Speaking on behalf of the One Asia Network, Nobuyuki Minami, President of Daizo Corp. of Japan, stated “Through this alliance, we are now ready to support our customers on a global basis. This is a major step forward in supporting our customers in the implementation of their projects: bringing innovation to the world.”

The alliance does not involve any cross shareholding participation; the manufacturing aspect of the agreement will include sharing of best practice in areas of; safety, manufacturing know-how and efficient practices. Technology exchanges will encompass both formulation and packaging developments, the sharing of aerosol science and technology, and the bringing together of creative dispensing solutions.

“Subliminal Seminar: Skills for Successful Closings” on October 3 at 6PM

Join The New Jersey Packaging Executive’s Club (NJPEC)on Thursday, October 3, 2013 at 6PM at The Manor in West Orange, NJ for a program that is sure to inform and inspire!

Business deals are built with a lot more than logistics and a handshake; layers and layers of psychology, timing, and intuition play huge roles in bringing us all the way from a proposal to a sale. Much of what makes a successful deal lies deep under the surface of our interactions.

Over the years, Donald Truss has been capturing many audiences’ attention by bringing this business psychology information to the surface. His presentation, The Turn: Subliminal Selling Skills for Successful Closings provides viewers with an in-depth look at how they can learn to read and manipulate these context clues for their own gain.

With years of experience as a business process consultant, sales trainer, marketing manager, and recruiter (over 3,000 positions filled!), Mr Truss has broken down the art of the deal into a learned series of steps that can be practiced and applied by anyone in any field. His Subliminal Seminar will have you reading business interactions at a whole new level of comprehension.

Who Should Attend? Purchasing, Packaging, Sales, Marketing, Executive Recruiters, Business Consultants, or anyone else who wishes to learn new ways to successfully achieve their business goals.

This event is open to members and non-members alike. All are invited to attend and enjoy Open Bar, Dinner Buffet, Beer Tasting, and Networking! The event will be at The Manor.

]]>http://www.spraytm.com/njpec-announces-fall-events.html/feed0Australian Aerosol Assn. offers Aerosol Regulatory Workshophttp://www.spraytm.com/australian-aerosol-assn-offers-aerosol-regulatory-workshop.html
http://www.spraytm.com/australian-aerosol-assn-offers-aerosol-regulatory-workshop.html#commentsTue, 03 Sep 2013 14:20:23 +0000http://www.spraytm.com/?p=4739Finding it hard to make head or tail of aerosol regulations? You are probably not alone as the aerosol industry, like the rest of the manufacturing sector, is sadly not immune to red tape.

However, there is an easy way for people working with aerosols to get to grips with the complex and often confusing regulatory regimes and requirements affecting this unique packaging format.

The Aerosol Association of Australia is re-running its successful Aerosol Regulatory Workshop at Macquarie Graduate School of Management in Macquarie Park, NSW, Australia, October 24, 2013.

Expert speakers will present an overview of:
• AS2278 (the ‘Aerosol Standard’) and its role in ensuring aerosol safety
• Classification: the GHS, Workplace Labelling and MSDSs
• Requirements for Therapeutics, Cosmetics and Disinfectants
• NICNAS – current and forthcoming requirements
• The new Work Health and Safety (WHS) Act – what it means and your new duties and responsibilities from a legal perspective
• Trade Measurement and the Average Quantity System
• Dangerous Goods Transport – classification and labeling
• Product Safety, Warranties and Recalls – including the mandatory reporting requirements of the Australian Consumer Law

The Australian Aerosol Association continues to build on its successful industry training program, and has now trained over 200 people in the basics of aerosol production, regulatory requirements and sustainability.

In a recent online survey, Echo Research, on behalf of The American Cleaning Institute (ACI), asked 1,777 U.S. adult consumers whether they or someone in their household spring cleans every year; 72% said spring cleaning was an annual ritual.

Eight percent said they spring clean every few years or less often, while 5% said every other year. Twelve percent said they never spring clean. Among those who do spring clean at one time or another, 76% target the bedroom, followed by the kitchen (73%), bathroom (69%) family room or den (61%) and dining room (45%).

Sixty-nine percent of respondents indicated that economic conditions have influenced their home cleaning behaviors. The top two changes include buying less expensive cleaning products and cleaning more themselves rather than hiring a service.

While women overall remain considerably more likely than men to claim sole responsibility for household cleaning, the gender gap continues to narrow, according to market research from Mintel. Roughly nine out of 10 men claim to at least share responsibility for housecleaning, and about one third say they take sole responsibility, up from just 17% in 2006.

Usage incidence of glass cleaners and general household cleaners, the two most widely used types of surface cleaners, has held steady between 2005 and 2012. Seven in 10 consumers agreed that disinfection has become more important to them when cleaning their homes, making it a key benefit for surface cleaner brands to incorporate into products.

Household surface cleaners showed 1.8% growth in 2012. Despite the overall economizing mindset of the past five years caused by difficult economic conditions, consumers continue to gravitate to new products that help them clean more quickly and easily or tackle old cleaning problems in new, more effective ways.

Mass merchandisers, warehouse clubs, and dollar stores continue to capture household surface cleaner sales. Together, these channels account for nearly 69% of category sales in 2012, up nearly two points since 2010 at the expense of traditional supermarkets and drug stores. Private label share is relatively low at 8.1% of category sales, said Mintel.

Green gains momentum

Continued consumer interest in more sustainable lifestyles has driven the U.S. market for “Green” (eco-friendly) cleaning products—including household surface cleaners and laundry products—to total retail sales of $640 million in 2011, up from $303 million in 2007, for a growth rate of 20%, according to the Packaged Facts report Green Cleaning Products in the U.S. Correspondingly, 41% of respondents to an online Packaged Facts consumer survey conducted in 2012 indicated that they had purchased or used natural, organic, or eco-friendly household cleaning/laundry products within the previous 12 months, up from 38% in 2009.

Cleaning products see increased competition

The All-Purpose segment continues to grow more competitive, said Mintel, and has
experienced only modest growth over the past two years, despite accounting for approximately half of all surface cleaner new product activity. Competition within this segment has become particularly varied and intense as brands from more specialized segments have introduced multi-surface and all-purpose line extensions.

Arm & Hammer Surface Cleaning Spray by Munchkin uses the natural cleaning power of baking soda to effectively clean toys, highchairs, counters, bath tubs and anything that baby touches. Only the fresh smell of lavender is left behind after using the specially formulated spray that is free of dyes, parabens and phthalates. The 16oz product is not tested on animals.

Scrubbing Bubbles Bathroom Cleaner with Color Power Technology, from S.C. Johnson & Son, Inc., has a specifically designed formula that sprays on blue and turns white as it cleans. It targets tough stains and safely cleans a variety of bathroom areas, including countertops, showers and toilets. It even works upside down, getting to hard-to-reach spots. The can is manufactured by DS Containers.

Scrubbing Bubbles Extend-A-Clean Power Sprayer has a continuous sprayer that helps provide better coverage for the whole bathroom, with a powerful formula of active cleaners that work continuously for days.

Mrs. Meyer’s Clean Day Radish Countertop Spray utilizes the formula of the company’s All Purpose Cleaner and added a special vegetable protein extract as a naturally fresh way to remove odors. It’s suitable for all non-porous surfaces, such as finished wood and tile floors, countertops, walls, porcelain and bathroom fixtures. The complementing Mrs. Meyer’s Clean Day Liquid Hand Soap can be used in the kitchen, bathroom or laundry room to wash and soften hard-working hands. It contains naturally emollient aloe vera, olive oil glycerin and fragrant essential oils.

Try to concentrate

Housecleaners who use refills or concentrates of surface cleaners are more likely to be motivated by money savings than by eco-friendliness, according to Mintel research, and promoting refills and concentrates as a common-sense way to economize could convince more consumers to try them.

Over 35 years ago, concentrated Simple Green All-Purpose Cleaner was formulated for the industrial marketplace, but has since made its way into homes. The environmentally-sensitive, non-toxic, cleaner/degreaser can be economically custom-diluted for various uses, such as a laundry soak or for cleaning floors and walls, pots and pans, windows, sinks and drains, and even greasy tools.

Its recently reconfigured, all-plastic trigger sprayer needed to be consumer-friendly, U.S.-made and tough enough to handle a wide range of chemical formulations. It was designed and supplied by MWV, Simple Green’s longtime packaging provider.

Replenish is the creator of a patented reusable concentrate mixing and delivery system designed to transform the way household products are packaged and consumed. The company’s flagship product is a multi-surface, ultra-concentrated household cleaner in a new reusable bottle system that makes cleaning easier, is better for the environment and saves money for consumers and retailers. Using a reusable, built-in, twist-on pod, consumers can measure the concentrate to make four bottles of Replenish cleaner. By encouraging reuse, Replenish has a goal of eliminating a billion bottles from landfills, a billion miles off roads and a billion pounds of chemicals out of the environment. Replenish’s products are developed and manufactured in the U.S. and tested to last for more than 10,000 trigger pulls.

We’re floored…

Floor cleaners/wax removers were strong performer between 2007 and 2012, due to the increasing prevalence of hard surface flooring, said Mintel.

Convenience-oriented products sell well, and this includes Endust Wood Floor Cleaner from Nakoma Products. Endust safely dissolves dirty and sticky messes, without leaving any dulling or oily residue. It restores wood’s natural shine, while Invertispray technology makes it easy to turn the can upside down and evenly apply at the press of a button. With no need of mixing, pouring, buckets or mess, the consumer simply points, sprays and cleans with a mop. Endust dispenses as foam to identify coverage and then liquefies to clean.

“As far as we know, the public has never been offered the opportunity to clean its wood floors with an aerosol product, which we believe is the world’s most convenient and efficient application method,” commented Jonathon Spagat, Nakoma Products.

Endust comes in a can from Ball; the product’s formula was developed by Chicago Aerosol, who also manufactured the product.

“Gee, your house smells terrific…”

The U.S. air freshener market declined by 4% between 2010 and 2011, decreasing from $2.18 billion to $2.09 billion in sales, according to Mintel. The market is expected to continue declining, shrinking to sales of $1.7 billion by 2017. These declines are expected largely due to continued economic challenges, as well as competition from scented household cleaners and scented candles.

Click on image for full size.

At 81%, sprays/aerosols command the highest usage among consumers. While most segments saw sales fall from 2010-12, the aerosols segment saw a 1.6% increase in sales and an increase of market share of 2.6 percentage points. Following sprays/aerosols are candles for burning (73%), candles for decoration (66%) and plug-ins (56%).

Consumers are purchasing air fresheners through a number of retail channels. The majority (nearly 70%) of air freshener sales are taking place within the “other channels” retail segment, which includes mass merchandisers, supercenters, club stores and dollar stores. Consumers are not looking for a boutique shopping experience when purchasing these functional products, explained Mintel.

Greater than two thirds of consumers reported usage (77%), while slightly less than a quarter reporting that they do not use air fresheners. Mintel reported that nearly 60% of consumers report that they mostly use air fresheners when they have an unpleasant scent in the home, while more than 50% report that they mostly use them to make their home smell fresh for guests.

This year, Reckitt Benckiser’s Air Wick brand launched six new limited edition fragrances that are inspired by the rare essence of U.S. national parks and are featured in its full range of air freshener products. As a supporter of the National Park Foundation, the official charity of America’s national parks, Air Wick developed the scents based on the unique flora and elements of popular U.S. parks. Scents include Grand Canyon (floral notes of delicate cactus blossoms in the warm summer breeze); Virgin Islands (tropical plumeria and sweet honeysuckle); American Samoa (coconut and island palms); Denali (pure cotton grass and fresh spring air); Gulf Islands (white sand beaches and summertime paradise) and Hawaii (exotic papaya and hibiscus flower).

The Sleep Serenity collection is the latest product innovation from Febreze, designed specifically for the bedroom. Its calming scents help create a soothing bedtime atmosphere needed for relaxation and a more peaceful night’s rest. Febreze Sleep Serenity’s technology helps eliminate odor and fills the bedroom with long-lasting, calming scents such as Moonlit Lavender, Warm Milk & Honey and Quiet Jasmine.

Give DIY a try…

Looking after homes is not just about cleaning, it’s also about maintaining one’s castle. Several new products were launched to make it easier for the Do-it-yourselfer.

Wood care company Minwax has taken its popular wood stain product—Minwax PolyShades One-Step Stain & Polyurethane—and made it even easier to use by putting it in a convenient aerosol spray can. The aerosols do not require a pre-stain wood conditioner, are suitable for working on hard-to-reach areas and can also be applied over existing stained or polyurethane-coated finishes for a quick wood and furniture update.

PolyShades aerosol is available in Pecan, American Walnut, Classic Oak, Mission Oak and Classic Black, in both gloss and satin sheens. It comes in a can from B-WAY that sports a valve from Summit Packaging and cap from Berry Plastics.

Contractors now have the ability to attain an invisible wall repair in less time with the introduction of Homax Pro Grade Wall Texture. Combining the control of a hopper gun and the convenience of an aerosol, Pro Grade Wall Texture matches a wide range of texture patterns. As a result, the new 25-ounce aerosol product helps reduce application time from a traditional two-day process to two hours. Repairs include punch-lists, patches and remodeling projects in bathrooms, kitchens, accent walls and closets. It’s suitable for tight spot repair applications as close as 6″, such as behind a toilet, as well as for applications on walls up to 125 square feet. The advanced formula is tinted for improved visibility during application and the no-prime feature saves the contractor time.

According to the company, the product is the first self-priming, low odor aerosol texture with a pressure adjustment toggle and pattern control dial for precise spray control. In addition, a pull trigger and ergonomic grip helps reduce finger fatigue for increased productivity. Without the hopper gun, the water-based product shortens cleanup tasks; it requires no tools, allowing cleanup to be simple and fast.

WD-40 Co. has added three new products to its WD-40 Specialist line. Developed at the WD-40 R&D Center, all of the new products are 50-state VOC compliant. Dirt & Dust Resistant Dry Lube (10oz) dries quickly and has a specially created formula for reducing friction and wear. An NSF Category H2 product, it also resists dirt, dust and oil, helps release molded parts, and lubricates slides, rollers and hinges. With a powerful stream that sprays up to five feet, Machine & Engine Degreaser (18oz) has a deep-foaming, penetrating action that quickly removes grease, oil, dirt and grime. Authorized for use under NSF Category C1, it is suitable for use on engines, gears, chains, industrial machinery, power equipment and metal tools, and helps make equipment run smoother, last longer and look like new. An NSF K2 registered product, Electrical Contact Cleaner Spray (11 oz) is safe to use on a variety of surfaces such as plastics, rubbers and metals. With its Smart Straw technology, it can easily clean oil, dirt, flux residue and condensation from circuit boards, controls, switches, precision instruments and electrical panels.

What’s next?

Housecleaning remains an essential chore, and financially-pressed consumers continue to look for ways to limit expenditures. As a result, more concentrates and reusable products are expected to launch in the future.

While household surface cleaner category sales have advanced little in 2007-2012, rising just 2% to a little less than $4.7 billion, but falling 8% on an inflation-adjusted basis, Mintel’s forecast calls for modest growth, with an increase of 7% between 2012 and 2017 to $4.9 billion. SPRAY

Click on chart for full size.

]]>http://www.spraytm.com/a-clean-sweep.html/feed0Argentina breaks one billion mark in aerosol production.http://www.spraytm.com/argentina-breaks-one-billion-mark-in-aerosol-production.html
http://www.spraytm.com/argentina-breaks-one-billion-mark-in-aerosol-production.html#commentsSun, 01 Sep 2013 04:01:48 +0000http://www.spraytm.com/?p=4708Camara Argentina Del Aerosol (CADEA) recently released Argentina’s aerosol production statistics for 2012. CADEA estimated a total production for 2012 of 1,037,500 units, up an impressive 12.3% from 2011, and the highest production level to date. Argentina experienced considerable increases in all categories, except for five segments that remained flat: Other, Lighter Gas, Veterinary, Automotive and Personal Care Other.

Personal care products were up 15.1% from 2011.

The big winner was the Bronzer segment, which showed growth of 50%. Also notable were Colognes & Perfumes (33.3%) and Deodorants/Antiperspirants (15.4%).

Hello everyone. Tinplated steel for both food containers and spray packaging is fabricated from steel sheet that has a very thin layer of tin on both sides of the sheet. The tin is electroplated to the steel sheet as it passes through an acid solution containing dissolved tin ions. The deposited tin layers on modern tinplate (tin coated steel) are typically less than one micron thick.

The structure of the tin layer is complex. There is a very thin layer of iron-tin alloy between the steel and the tin, and a thicker tin layer above the iron-tin-alloy layer. Other layers of materials, such as chromium and oil, are deposited on the tinplate sheet after the tin is electroplated on the steel sheet.

Click image for full size

The surface of the steel sheet is not homogeneous, and the tin coating is not continuous. Traditional 0.2 pound tinplate has a surface that is approximately 20% holes. These holes expose either the base steel sheet or the iron-tin alloy.

Figure 1 has a photomicrograph of a hole in traditional tinplate, which shows that the shape is typically irregular.

Within the last decade, a different type of hole-morphology appeared in tinplate from different sources, as shown in Figure 2. The shape for the “new” holes is circular at the top.

The tinplate for the photomicrograph in Figure 2 is from an aerosol container that was not exposed to a product. The tinplate with both types of holes complies with the ASTM standard for tin mill products (tinplate).

Circular holes in nickel coatings used for electronic circuits are often the result of changes in the phosphorous concentration in the plating bath chemistry. We do not know if the same phenomenon causes the circular holes found in the “new” tinplate. However, the differences in the two tin hole-morphologies suggest that the electro deposition process for the traditional tinplate (Figure 1) is most likely different from the process for the “new” tinplate (Figure 2).

Click on image for full size

We’ve seen one instance where pit perforations had the same shape as the holes in Figure 2. However, we’ve seen numerous other instances where the corrosion behavior with the traditional holes (Figure 1) and the “new” holes (Figure 2) was the same. In other words, so far, it has been our experience that the hole-morphology does not affect corrosion in most instances.

I’ve been asked if corrosion testing could be skipped when changing from one tinplate vendor to another or when adding another vendor. Several decades ago I believed that the change could be made without corrosion testing.

However, it is unknown at this time if one or the other hole-morphologies in tin coatings are more or less corrosion-susceptible than the other. Consequently, we recommend corrosion testing when switching or adding an alternate tinplate container vendor, because the hole-morphology for each vendor might be different.

Please send your questions/comments/suggestions to rustdr@pairodocspro.com. Visit www.pairodocspro.com for more info about our Elements short course. Back issues of Corrosion Corner are available on CD from ST&M. Thanks for your interest and I’ll see you in October.

The deadline for completing the U.S. Occupational Safety & Health Administration’s (OSHA) Globally Harmonized System for Classification & Labeling of Chemicals (GHS) Hazard Communication Standard (HazCom 2012) training is rapidly approaching. All employers must train those employees who may be exposed to hazardous substances on the product marking, labeling and Safety Data Sheet (SDS) aspects of the new GHS standard which was adopted, in part, on March 26, 2012.

Particular attention must be given to the pictograms, and hazard and precautionary statements, as well as the sixteen sections of a properly formatted SDS.

Testing & Certification Recommended

OSHA requires under the new Hazard Communication Standard (HCS) that employers “…provide employees with effective information and training on hazardous chemicals in their work area at the time of their initial assignment, and whenever a new chemical hazard the employees have not previously been trained about is introduced into their work area.”

Although OSHA does not mandate that a written exam or certification be offered in association with the training, employers are strongly encouraged to do so for a number of reasons.

First, a written exam is a useful tool to measure comprehension of this most important topic. Additionally, the certification is a method in which to prove to inspecting agencies that the required training was, indeed, given.

Second, a written exam and certification may be used to satisfy the U.S. Dept. of Transportation’s (DOT) General Safety Training requirement. DOT requires that all hazmat employees as defined in Title 49, Code of Federal Regulations (CFR), section §171.8, receive General Safety Training, in addition to General Awareness & Familiarization, Security awareness, and Function-Specific training. Driver training and Detailed Security Plan training may also be required for operators of motor vehicles used to transport placardable quantities of dangerous goods, or for facilities that offer into transport or transport quantities of hazardous materials requiring registration with DOT’s Pipeline & Hazardous Materials Safety Administration (PHMSA).

In order to qualify for DOT General Safety Training, the training offered must fulfill the requirements of 49 CFR Part 172, subpart H, and sections §172.702 and §172.704, in particular.

DOT’s General Safety Training Requirement states that:

“…each hazmat employee shall receive training concerning:

(i) Emergency response information required by Subpart G of Part 172;

(ii) Measures to protect the employee from the hazards associated with hazardous materials to which they may be exposed in the work place, including specific measures the hazmat employer has implemented to protect employees from exposure; and

(iii) Methods and procedures for avoiding accidents, such as the proper procedures for handling packages containing hazardous materials.”

Although the DOT’s General Safety Training requirement is focused on the hazmat employee in particular, OSHA’s HazCom 2012 training is broader and will include, by definition, all hazmat employees because that subset of your workforce could be potentially exposed to hazardous chemicals during shipping, receiving, handling and transportation.

The emergency response requirements of 49 CFR Part 172, Subpart G specify that a 24-hour emergency response telephone number be provided for a hazardous materials emergency. This is generally the emergency phone number found in Section One (Identification) of a properly formatted SDS under the new standard (see Appendix D to 29 CFR 1910.1200, Table D.1, Heading 1 – Identification). It also requires that emergency response information must be provided that addresses accidental exposures, fires, spills, leaks and other emergency situations. This corresponds to Sections 4 (First Aid Measures), 5 (Firefighting Measures) and 6 (Accidental Release Measures) of a properly formatted SDS under the new standard.

Measures to protect employees are addressed in Section 8 (Exposure Controls/Personal Protection), and Section 11 (Toxicological Information) of the new SDS. Methods and procedures for avoiding accidents are addressed in Sections 7 (Handling & Storage) and 13 (Disposal Considerations) of the new SDS.

Few Modifications Needed

Therefore, it makes sense to consider modifying your existing HazCom 2012 training program to address the elements of the DOT’s General Safety Training requirement, and to provide a written exam and certification in order to satisfy both OSHA’s HazCom 2012 training and DOT’s general Safety Training requirements.

In fact, DOT states in 49 CFR §172.704(b) that “…training conducted by employers to comply with the hazard communication programs required by the Occupational Safety & Health Administration of the Dept. of Labor (29 CFR 1910.120 or 1910.1200) or the Environmental Protection Agency (40 CFR 311.1), or training conducted by employers to comply with security training programs required by other Federal or international agencies, may be used to satisfy the training requirements in [49 CFR §172.704(a)] …” to the extent that such training addresses the training components specified in [49 CFR §172.704(a)].

In the new OSHA HazCom rule, OSHA states in 29 CFR 1910.1200(h)(3)(iv) that the employee training shall include, at least, “…an explanation of the labels received on shipped containers and the workplace labeling system used by their employer; the safety data sheet, including the order of information and how employees can obtain and use the appropriate hazard information.”

Only a few modifications to the training program need be made. Essentially, the HazCom2012 program modifications should include an explanation of the various DOT marks, labels and placards for those hazardous materials that are shipped to or from the facility, a written test, and a Certificate of Completion, awarded upon successful completion of the training. Many of the GHS pictograms are also consistent with DOT hazard warning labels, except that they have different background colors and sizes so it would not be difficult for the user to understand the properties and hazards associated with DOT-regulated chemicals.

Important Note

It is important to note, however, that DOT requires recurrent training be given to all hazmat employees at least once every three years. Although OSHA does not specify that recurrent training is required (except when a new chemical or hazard is introduced into the work area), employers are strongly encouraged to offer the HazCom 2012 training routinely (e.g., annually).

By providing refresher training you will better educate your work force on the hazards associated with chemicals in the workplace and develop a deeper understanding of the new rules. SPRAY

CARB

On August 7, the California Air Resources Board (CARB) released their proposed amendments for the Consumer Products rule and the Aerosol Coating rule. There are now 45 days to review and comment on these proposed changes. These proposed amendments are to be adopted on September 26, 2013.

Industry has been working with CARB for more than a year on these amendments. Below is a summary of each regulation:

Aerosol Coating Proposed Changes

Any product that meets the definition of an aerosol coating is regulated; this means marketers need to carefully review labels so that products are in the right category, otherwise the product could default to the lowest general-purpose coatings category limit.

New categories and New MIR limits for some categories called Specialty Coatings (A) effective date 01/01/2017.

All other specialty coatings were capped. New MIR limits effective 01/01/2015.

More reporting requirements.

Definitions added or changed to provide clarity.

Overall, the largest issue is that the General Coating limits will be very challenging to meet. Anyone that produces aerosol coatings should review this regulation completely to ensure their products are compliant and categorized properly. This will be another area where CARB enforcement will target. Therefore, we have a little over a year to make sure the Specialty Coatings label claims are correct.

Consumer Products Proposed Changes

Multi-purpose Solvent and Paint Thinner have new limits and requirements in the South Coast Air Quality Management District (SCAQMD).

Aerosol Adhesives limits for Spray & Mist product categories have new limits as of 01/01/2017.

Aerosol Multi-purpose Solvent and Aerosol Paint Thinner have been defined and regulated with a VOC limit as of 1/1/2016.

Addition of Single Use General Purpose Cleaner and Single Use General Purpose Degreaser definitions.

VOC exemption for HFO-1234ze.

Two of the bigger issues in this rule were the changes to the Mutli-purpose Solvent and Paint Thinners category, which apply to the SCAQMD area. The dropping of the Low Vapor Pressure Volatile organic Compound (LVP-VOC) definition changes due to the upcoming scientific studies was proper and provides for science to prevail on this issue

Again, I encourage everyone that manufactures a Consumer Product to review these proposed changes completely. Industry has 45 days to review and comment on this proposal.

To date, no individual states have adopted the new Ozone Transport Commission (OTC) model rule that has an effective date of 1/1/2014. State activity is expected to start this fall.

Green Chemistry

The Safer Consumer Product Regulation was released on July 24 and will be effective in October 2013. To review, visit: http://tiny.cc/4p9f1w

NCWM

The National Conference on Weights & Measures (NCWM) was held in Louisville, KY in July. During the bag-on-valve (BOV) meeting, a manufacturer provided a presentation and proposed changes to the Laws & Regulation (L&R) committee. The proposal was to add the wording “non-aerosol” to the label and be able to have the net content declared in volume (instead of weight) for some BOV products that met a certain criteria.

Several people in the room, including members of the National Aerosol Association (NAA) opposed this proposal. The L&R committee is reviewing comments. Its next meeting is in January 2014, where hopefully a plan to proceed will occur. SPRAY

]]>http://www.spraytm.com/4672.html/feed0Croda Inc will present a Trends-Forward Educational E-seminar Series in Fall 2013http://www.spraytm.com/croda-inc-will-present-a-trends-forward-educational-e-seminar-series-in-fall-2013.html
http://www.spraytm.com/croda-inc-will-present-a-trends-forward-educational-e-seminar-series-in-fall-2013.html#commentsMon, 26 Aug 2013 15:49:50 +0000http://www.spraytm.com/?p=4727Croda Inc. announced that its upcoming Fall personal care e-seminar series will unveil a new format for the season, connecting its events within the framework of the future trends identified in the first event. On September 12, Croda’s trends expert, Christophe Toumit, will kick off the 4-event series with “Understanding the Multi-Faceted Woman,” a presentation exploring three new beauty trends that are shaping the personal care market. This forward-facing trends presentation will set the framework for three subsequent events focusing on the multi-faceted woman and her position in the personal care market.

On October 2, Croda’s skin care experts will share a detailed overview of the differences among various skin types and their respective needs in “Skin Diversity Explained.” Later in the month (Oct 23), the topic of natural actives will be applied to personal care needs on a multi-generational level in “Super Naturals: Addressing Cross-Generational Beauty Needs.”

Closing out the fall program, “Novel Conditioning: Opportunities for the Modern Woman” (Nov 6) will delve into the innumerable functions, applications and formats for hair conditioning for an entire spectrum of hair needs.

To register: www.croda.com/na/pc/EseminarsFall2013

]]>http://www.spraytm.com/croda-inc-will-present-a-trends-forward-educational-e-seminar-series-in-fall-2013.html/feed0Get ready for Luxe Pack Monaco!http://www.spraytm.com/get-ready-for-luxe-pack-monaco.html
http://www.spraytm.com/get-ready-for-luxe-pack-monaco.html#commentsMon, 26 Aug 2013 15:37:25 +0000http://www.spraytm.com/?p=4721The 26th edition of luxury packaging event Luxe Pack Monaco will take place Oct. 23–25 at the Grimaldi Forum in Monaco. There will be a record number of nearly 400 exhibitors, 8% of whom are exhibiting for the first time. The conference program includes “Behind the Walls of Creation: Two Decades Dedicated to the World of Perfume” with Luxe Pack Monaco guest of honor Francis Kurkdijan, “How Can Luxury Products Develop for Tomorrow?,” “Eco Design, Refills, Bulk Recycling,” “Brand and Luxury Packaging,” “Cosmetic Regulations,” “Chinese Luxury Market Trends & Consumer Expectation,” “The Innovations Factory,” “Luxury Consumption Patterns Across the World: The Impact of Religion,” and “Packaging Between Sense & Sensibility: Create Meaning Using Semiotics.”

On the topic of semiotics, Luxe Pack Monaco will offer free individual semiotic consultants from business school professor Flore Maman Larrufie, Director of SémioConsult. The sessions can help brands assess the emotional potential of their packaging, as well as decode hidden meanings in packaging.

The Luxe Pack in Green Award Ceremony will recognize the “best innovative product” from the Luxe Pack in Green zone, a dedicated area that highlights exhibitors integrating sustainable development criteria into their packaging that offer proven value for luxury brands.

The Luxe Pack Trends Observer roundtable will include insights from an expert panel on packaging design trends as illustrated by examples of new products.

New this year is Luxe Pack Essentials, where design and trend specialists will share discoveries and reflections, including promising new products, technical innovations and know-how. Luxe Pack Monaco is also renewing the Luxe Pack Innovations Forum, which will unveil exhibitors’ latest innovative solutions. Visit luxepack.com.

]]>http://www.spraytm.com/get-ready-for-luxe-pack-monaco.html/feed0CALL FOR APPLICATIONS: NJPEC’s Package of the Year Awardhttp://www.spraytm.com/call-for-applications-njpecs-package-of-the-year-award.html
http://www.spraytm.com/call-for-applications-njpecs-package-of-the-year-award.html#commentsMon, 12 Aug 2013 14:13:56 +0000http://www.spraytm.com/?p=4613CALL FOR APPLICATIONS: NJPEC’s Package of the Year Award

DEADLINE SEPTEMBER 13

Submit your package today for NJPEC’s Package of the Year Awards! Designed to spotlight the best in packaging across multiple industries, NJPEC will host the Package of the Year Awards on Thursday, November 14, 2013 The Madison Hotel in Morristown, NJ.

The Package of the Year Awards is an ideal way to gain industry exposure and business for your company or brand. Industry categories include, but are not limited to: Health and Beauty / Food and Beverage / Pharma / Fragrance / Color Cosmetics / Household and Industrial / Label Graphics / Personal Care / Promotional.

A panel comprised of packaging and branding industry veterans has been formed to evaluate the best of the best and select the winners. Judging criteria involves Design Excellence, Shelf Impact, Uniqueness, Cost Effectiveness, and Graphic Presentation.

Visit the NJPEC website – www.NJPEC.com - to view full guidelines and download the Package of the Year Application Form. Deadline to apply is September 13.

Sunny skies prevailed yet again at the Eastern Aerosol Association (EAA) annual golf outing on Aug. 7, held at the Crystal Springs Resort in Hamburg, NJ.

The First Place team was comprised of Bill Geisel, EXAL; Dennis Smith, Precise Packaging; Luke Magnant, Mondelez; and Joe Everard. Second Place went to the team made up of Bart Bastian, Spray Products; and Bill Auriemma, George Sehringer and Brock Manner, all of Diversified CPC.

George Buckland, DS Containers won the Putting Contest. Long Drive winners were David Deatton and Chris Nyarady, Montebello. Closest to the Pin winners were Greg Wise, Ball Corp.; and Bob Swiatecki, American Spraytech.

The average age of cars on the road is at a record high of 11 years, according to market research firm Mintel. Consumers who own older cars are interested in different types of automotive cleaning products than new-car buyers (deep cleaning products such as scratch removers, for example). Given that these consumers are likely putting off of buying a new car for cost reasons, they may be less likely to pay for a professional car wash as well, relying on at-home cleaning products.

However, there is little difference between household income groups regarding how often they clean their vehicles at home. According to Mintel, this demonstrates that car washing is a universal activity, as both luxury and used cars get dirty. However, consumers of different income levels will likely be interested in different products: luxury cars may need additional polish for more detailed cleaning; used cars may need restoration products for older paintwork.

Blame it on the kids…
Households with young children are one of the most opportune markets for auto cleaning product manufacturers. The difference in interior cleaning product purchasing behavior between families with children and those without children is significant: approximately 39% of respondents with no children under 18 did not purchase any cleaning products, as compared to just 21% of those with children, said Mintel.

Factors at play include the increased mess caused by children (and family pets), as well as a change in lifestyle brought on by being a parent—a possible increase in the number of vehicles, more frequent use of vehicles and a need to save on expenses (such as a trip to a professional car wash), etc.

Consumers aged 18-24 (who are likely buying their first car and learning to care for it) were more likely than other age groups to purchase interior cleaning products, including air freshener sprays (45%) and carpet cleaner (34%).

Washing car interiors at home, using store-bought products, is the most common and least-expensive auto cleaning activity. Cleaning at home may also be a leisure activity that families can share together on weekends, a factor that is supported by Mintel data that indicates 50% of vehicle owners say “cleaning the car/truck is a good family exercise.”

Cleaning Vehicles Inside & Out
Whether considered a “leisure activity” or not, cleaning vehicles is a necessary task. To help,Empack Spraytech Inc. launched its new emzone Rim Cleaner and emzone Rim Protector to its Tire & Rim Care program. Emzone Rim Cleaner aggressively cleans and dissolves brake dust, road grime, grease and dirt to give rims a brilliant shine. Emzone Rim Protector forms an invisible protective barrier that helps repel brake dust, road grime, grease and dirt, which keeps rims clean longer and makes cleaning easier. One application lasts up to four weeks. The new items complement the emzone Foaming Tire Shine currently in the line. Its special formula lifts and dissolves dirt, leaving tires with a high gloss finish. Used together, the products help ensure that tires and rims look their best. Emzone Rim Protector and emzone Foaming Tire Shine sport valves from Precision Valve and caps from Cobra Plastics.

Champion Brands Wipe-R-Clean Glass Cleaner is a safe and easy-to-use cleaner that dissolves smudges, film, scum, smears, bugs and other soil. A suitable cleaner for windows, mirrors and other glass surfaces, the product is streakless and ammonia free, as well as compliant for sale in North America.

3M Auto Care relaunched its vehicle care collection, utilizing redesigned containers. The 11-sku line includes Wheel & Tire Cleaner, Tire Restorer, Quick Wax and Leather & Vinyl Restorer in a trigger pump. TricorBraun received a 2013WorldStar International Packaging Award for the 3M Auto Care Products, whose packaging was redesigned with an eye toward environmental compatibility and economy. According to TricorBraun, the newly-designed packaging is manufactured with PET, including 25% post-consumer recycled material. The 3M products were distinguished by an environmental commitment that annually eliminates 63,063 pounds of PET from the waste system. The new containers lowered distribution costs by reducing package weight 12.5% and also accepted a less costly closure.

The Armor All/STP Products Co. launched Custom Shield Coating, a product that allows consumers an opportunity to ditch the automotive bra on the front of their car for a sleeker look. New Custom Shield Coating is a temporary, spray-on, peel-off veneer that allows consumers to protect a vehicle’s paint and body from the elements. The technology comes in the colors of Black, White and Clear, which give consumers the ability to create a temporary customization, such as racing stripes or team colors. The product helps protect front grill, hood and rocker panels from scratches and nicks caused by flying debris. It can also be used on wheels to protect from brake dust build-up, is weather resistant and can last up to three months. It’s easy to apply, as its aerosol delivery allows for a simple application that dries quickly. Removal never requires tools—when it’s time to remove, just peel off and throw away.

Valvoline Heavy Duty Brake Parts Cleaner instantly removes brake dust, brake fluid, grease and grime, and contains a powerful, non-chlorinated formula designed to effectively clean brake parts and CV joints. The penetrating formula is fast-drying, non-chlorinated, evaporates quickly and leaves no residue. It helps stop brake squeal and chatter and can be used for all ABS, disc and drum brakes. It’s VOC compliant in all states except California, with a California VOC compliant formula available.

Valvoline Extra Strength Starting Fluid has been formulated to deliver maximum starting strength. Ether and heptane are blended together to produce a starting fluid which has a low freezing point, high vapor pressure, low flash point (ignition), high BTU content (starting power) and an upper cylinder lubricant for protection. It starts engines quickly and helps reduce drain on batteries, is compatible with gasoline or diesel engines and contains upper cylinder lubricant. It is suitable for year-round use in cars, trucks, lawn mowers, chain saws, marine engines and motorcycles.

For extreme conditions…Ice-Off Windshield Spray De-Icer from CRC Industries helps melt ice, snow and frost from windshields on contact. It also thaws frozen locks, is effective to sub-zero temperatures, and helps prevent re-freezing. It is harmless to car finishes, and can be used on car and truck windows, locks, latches and wipers. CRC Ice-Off utilizes Powerjet technology with a new Powerjet spray nozzle from Precision Valve that produces a burst of product to forcefully break apart ice and defrost windows instantly.

Penray Plus Tire Fix Plus Emergency Tire Inflator from The Penray Companies, Inc. is a safe method to temporarily repair a tire. Utilizing its special “Leak Detective,” the product is designed for use in most passenger cars, trucks, trailers, lawn tractors, ATVs or pneumatic-type tires. The special latex foam formula helps seal most tread area punctures while partially inflating the tire. It requires no jack or tools, which helps reduce the hazards of roadside tire changing. It’s safe on tire pressure monitoring devices when used as directed, has a non-flammable formula and easy clean-up with water.

Motor Medic Thrust Quick Starting Fluid from Radiator Specialty Co. helps promote quick starting of gasoline and diesel engines under extreme cold conditions down to -65°F. The product—containing upper cylinder lubricant and corrosion inhibitors—helps save the batteries and ignitions of autos, buses, trucks, tractors, outboard motors, chain saws and construction equipment that have either gasoline or diesel engines. It contains no chlorinated solvents and meets current low VOC regulations. The cans for all three products are manufactured by DS Containers.

Rust-Oleum Automotive’s LeakSeal Rubberized Coating fills and seals leaks and cracks, providing a flexible water-tight seal that prevents moisture penetration, rust and corrosion. The high-build formula was specifically developed to fill cracks, gaps and holes while maintaining flexibility, even with temperature changes and UV radiation. LeakSeal can be used on metal, vinyl, plastic, PVC, concrete and other surfaces year round. SPRAY

This month I thought it would be interesting to provide a list of corrosion tidbits that are relevant to spray package corrosion. I’ve alphabetically arranged the various tidbits into several categories.

Analyzing & interpreting corrosion data
• Extremes in corrosion data should not be dismissed as outliers
• Variability in corrosion data is a fact-of-life
• Variability is best dealt with by examining multiple replicate
samples at each storage test examination interval

Corrosion inhibitors
• There is no one-size-fits-all corrosion inhibitor
• The chemical composition of your formula determines if a given chemical is a corrosion inhibitor for your formula
• Different types of corrosion often require different types of corrosion inhibitors

Formula chemistry
• Fragrances often provide some degree of corrosion inhibition, with a few exceptions, such as fragrances based on vanillin
• The chemical composition of your formula determines if your formula is corrosive toward a given type of spray packaging
• Water contamination could transform a benign anhydrous formula into a voracious package-eater
• Higher formula pH does not always prevent spray package corrosion
• Increased temperature could cause corrosion by degrading formula ingredients and destabilizing emulsions

Spray Package Materials
• No one type of polymer or metal spray package material is more corrosion-resistant than the others
• No one type of spray package is resistant to corrosion by all formulas
• Doubling the thickness of an aerosol container coating does
not usually double the container service life

Testing
• Temperature does not accelerate the rate of corrosion of spray package metals and polymers
• Shorter storage test times have higher risk; for example, the corrosion risk is approximately 31% after three months of storage testing
• Storage tests should be conducted for at least one year if you want a risk of 2% to 7%

Types of Corrosion
• General corrosion and pitting corrosion are very different types of corrosion
• General corrosion typically does not shorten spray package or aerosol valve service life
• General corrosion could degrade product efficacy, such as fragrance
• Pitting corrosion causes package leaking and shortens package service life
• Vapor phase corrosion (head space corrosion) and liquid phase corrosion are very different forms of corrosion
• Vapor phase corrosion could be general corrosion, pitting corrosion or both
The corrosion tidbit list is actually much longer than what can be found in this article. Hopefully, you’ll find this abbreviated list useful when developing spray products and line extensions to existing spray products, as well as specifying packages and package-materials for spray products.

If you want to share some of your corrosion tidbits, I’d be happy to include them in a future issue.

The examples shown in this month’s Corrosion Corner are a few of those used in our Elements of Spray Package (Aerosol) Corrosion short course. This 1.5 day short course provides an introduction to all aspects of spray package corrosion, corrosion testing and corrosion prevention.

More info: www.pairodocspro.com. Please send your questions/comments/suggestions to rustdr@pairodocspro.com. Previous Corrosion Corners are available on CD from ST&M. Thanks for your interest; see you in September.

FEA International Aerosol Awards
Additionally, AEDA is hosting the second FEA International Aerosol Awards. Open to aerosol component manufacturers, fillers, marketers and retailers the world over, the Awards center on the ever-important themes of innovation and sustainable development, and aim to celebrate the genius, creativity and technical excellence of the international aerosol industry.

All products entered must have been launched on the market between January 2011 and June 2013. The winners will be announced and the Awards presented at the Gala Dinner of the FEA International Congress & Exhibition in Madrid on Sept. 25. SPRAY

]]>http://www.spraytm.com/fea-gears-up-for-madrid-conference.html/feed0CARB, OTC and NCWMhttp://www.spraytm.com/carb-otc-and-ncwm.html
http://www.spraytm.com/carb-otc-and-ncwm.html#commentsThu, 01 Aug 2013 04:01:35 +0000http://www.spraytm.com/?p=4536CARB
In early July, the California Air Resources Board (CARB) staff released, for preliminary review, the Aerosol Coatings amendments. Remember, in May, CARB delayed the Board Hearing until September 2013. The good news is not much has changed in the Aerosol Coating amendments. The amendments change definitions, as well as volatile organic compound (VOC) limits, and some new categories have been added. The biggest change to this regulation is that all products that meet the definition of Aerosol Coating need to fit into a category. This is slightly different than Consumer Products, where a product can be exempt from the regulation. Therefore, if you make Aerosol Coatings, make sure you categorize them and that the product meets the appropriate VOC limit for that category.
I encourage all marketers and manufacturers of Aerosol Coatings to review these amendments.

No word yet on the Consumer Products amendments. These amendments have to do with some definition changes, changes to Aerosol Adhesive VOC limits and, of course, the LVP-VOC definition.

CARB has gone ahead and approved the study of LVP-VOC compounds. Hopefully, there will not be much change in position since CARB’s workshop in April, when CARB dropped the changes to the LVP-VOC definition. The staff needed to post its final draft by the end of July; thus the document needs to be released soon.

OTC
The Ozone Transport Commission (OTC) held its annual meeting in New Haven, CT on June 13. The meeting was well attended and all states were present.

The OTC had a day-long meeting to discuss numerous issues with air quality. Consumer Products are only one issue that OTC deals with. The most important topic the OTC has is migration of air pollution into and between OTC states. A significant amount of time was spent on this issue. At this year’s meeting, Janet McCabe, Deputy Assistant Administrator of the U.S. Environmental Protection Agency (EPA), stated that the OTC’s work on developing model rules is greatly appreciated.

This seemed to be a lead in to a topic raised by the head of the Stationary Source Committee for the OTC, Ali Mirzakhalili from Delaware. Mirzakhalili stated that the OTC would be requesting the EPA to adopt the OTC Model rules for Consumer Products and Architectural Coatings. Deputy McCabe stated EPA would consider such a request, but its resources are tied up. Later, OTC made the formal votes to have OTC request EPA to adopt the current model rules for Consumer Products and Architectural Coatings.

These requests will be formally sent to EPA for consideration. This means if EPA decides to adopt the OTC model rules then the original CARB rules become National Rules. This is the reason why working with California is extremely important. If the original rule developments are successful, then the industry can live with these regulations. Now we need to wait to see what EPA’s actions will be.

NCWM
The National Conference on Weights & Measures (NCWM) met in Louisville, KY on July 14–18. The issue of whether bag-on-valve products will need to declare net contents by weight or volume was once again discussed. More on this in the September issue. SPRAY

On occasion, I will receive a frantic call from a customer whose shipment of dangerous goods has been frustrated for one reason or another. Such is the case this past week, when a forwarder contacted me regarding a shipment that was not declared properly by the shipper. I offered to assist the shipper and forwarder by preparing the dangerous goods (DG) declarations. The consignment consisted of three aerosol cans in a fiberboard which was then overpacked in a larger wooden crate, loaded in an intermodal freight container, bound for Australia via Shanghai, China.

After reviewing the Safety Data Sheet for the product, I was able to quickly determine that the flammable aerosols were permitted to be shipped as limited quantities. I prepared the DG declaration for the shipper to sign and declared the goods as UN1950, AEROSOLS, 2.1, LTD QTY.

Well, the shipment was promptly rejected by the steamship line! This immediately created a firestorm of emails between forwarder, shipper, myself and the steamship lines’ customer service representatives—28 in all, to be exact. The quote-unquote “expert” for the steamship line, who touted his 15 years of experience in his email, claimed that the International Maritime Dangerous Goods (IMDG) Code required that the Gross Weight (GW) and Net Weight (NW) be provided on the DGD.

In fact, the IMDG Code does not require the Net Weight (other than net explosive weight for class 1 explosives). The IMDG Code actually states (in Section 5.4.1.5.1):

Total quantity of dangerous goods
Except for empty uncleaned packagings, the total quantity of dangerous goods covered by the description (by volume or mass as appropriate) of each item of dangerous goods bearing a different Proper Shipping Name, UN Number or packing group shall be included. For class 1 dangerous goods, the quantity shall be the net explosive mass. For dangerous goods transported in salvage packagings, an estimate of the quantity of dangerous goods shall be given. The number and kind (e.g. drum, box, etc.) of packages shall also be indicated. UN packaging codes may only be used to supplement the description of the kind of package (e.g., one box [4G]). Abbreviations may be used to specify the unit of measurement for the total quantity.

It was also interesting to note that the IMDG Code further states that:

The number, type and capacity of each inner packaging within the outer packaging of a combination packaging is not required to be indicated.

After quoting what the IMDG Code actually requires, the steamship line changed its position and said that it was, essentially, a business requirement for their partnering line. Now, I don’t have any objection to providing the net weight (NW) in addition to the gross weight (GW). In fact, it is a good idea and is strongly recommended. What I object to is the fact that the steamship line, in this case, was imposing requirements that were not, in fact, requirements and making claims that the documents, as offered, were in violation of the rules.

Wouldn’t it have been easier to have known what the regulatory requirements and business requirements were up front? Often there are misinterpretations of the rules and business policies are often mistaken for regulatory requirements. In my opinion, the carrier should clearly communicate its requirements up front, in much the same manner that carriers have filed and published variations in air regulations. These business requirements or other restrictions should be prominently posted on their websites and other communiqués to existing and potential customers.

Likewise, I am of the opinion that the shipper and freight forwarder should make it a practice to ask if there are any restrictions above and beyond the minimum regulatory requirements. I have often suggested to customers that they host an annual carrier conference whereby they invite their ground, air and vessel carriers in to discuss the types and quantities of dangerous goods that they offer into transportation, and offer or make available packaging and documentation examples so that they can eliminate or significantly reduce the number of frustrated shipments that might occur. It would give both parties an opportunity to discuss some of the potential roadblocks and to jointly resolve these difficulties before they become serious issues.

I also recommend that you have a national account representative for each carrier through which to resolve some of these conflicts that will invariably arise. Often, clients will get two different answers from two different people on two different days. It is frustrating and counter-productive, to say the least!

The Consumer Specialty Products Association (CSPA) congratulates Gina McCarthy on her confirmation as the new U.S. Environmental Protection Agency (EPA) Administrator. CSPA recognizes the priorities, challenges and opportunities ahead on air quality, water, pollution prevention, chemical management issues, and antimicrobials and conventional pesticides. The Association welcomes the opportunity to work with Administrator McCarthy as she takes on her new role.

“Air quality issues, implementation of the Pesticide Registration Improvement Extension Act (PRIA III), enhancements to the Design for the Environment program and modernization of the Toxic Substances Control Act (TSCA) are among the top issues for our industry. We look forward to continuing the dialogue on these and other issues with Administrator McCarthy,” said CSPA President and CEO Chris Cathcart.

]]>http://www.spraytm.com/cspa-comments-on-confirmation-of-gina-mccarthy-as-new-epa-administrator.html/feed0“Huffing” bill would define inhalants as intoxicantshttp://www.spraytm.com/huffing-bill-would-define-inhalants-as-intoxicants.html
http://www.spraytm.com/huffing-bill-would-define-inhalants-as-intoxicants.html#commentsMon, 22 Jul 2013 14:36:32 +0000http://www.spraytm.com/?p=4505Two Wisconsin bills are aimed at changing state laws about a dangerous substance. Inhaling aerosol sprays, also known as “huffing”, is illegal, in some ways, but not in others.

Two Wisconsin bills are aimed at a dangerous, yet readily accessible substance: inhalants. Under current state law, inhalants like keyboard cleaner, aren’t defined as intoxicants. That means when someone uses inhalants, and then gets behind the wheel, they can’t be charged with OWI.

“So that person, on the roadway, in certain circumstances, can be as dangerous, or more dangerous than a person under the influence of alcohol, or even prescription medications because they can start to hallucinate, they can black out with no notice, and their car literally becomes a weapon without a driver at the controls,” says Sgt. Quella.

In April, an Eau Claire woman, accused of huffing, crashed her car into city hall. Officers say they found items in her car that led them to believe she may have been huffing. She was charged with OWI, but not because of huffing.

“She had other drugs in her vehicle. Is it very likely that she was huffing before the crash? Yes, but there were other things,” explains Sgt. Quella.

What police can charge the driver with are things like possession of a hazardous substance, a misdemeanor, or reckless driving. But police say that doesn’t get at the root of the problem.

“Whenever that person is not held accountable, I think that there’s a higher likelihood that that person will take to the road again and another likelihood that that person may not get the court-ordered chemical dependency help that he or she needs,” Sgt. Quella says.

Last year, a state appeals court threw out an intoxicated driving charge for an Appleton woman, ruling that the specific chemical the woman “huffed” isn’t an intoxicant. That chemical, known as DFE, is a common ingredient in most aerosol sprays.

“It would be a shame for a case to be lost because the active ingredient in the gas dusters are not covered under statute,” says Sgt. Quella.

Two bills, one in the senate and one in the assembly, would change that.

“A change in legislation would give us another tool to keep the public safe,” says Sgt. Quella.

One bill has been passed by the assembly and a public hearing was just held this past week on both bills.

Source: WQOW.com

]]>http://www.spraytm.com/huffing-bill-would-define-inhalants-as-intoxicants.html/feed0Luxe Pack New York Announces Dates and New Venue For Its 12th Editionhttp://www.spraytm.com/luxe-pack-new-york-announces-dates-and-new-venue-for-its-12th-edition.html
http://www.spraytm.com/luxe-pack-new-york-announces-dates-and-new-venue-for-its-12th-edition.html#commentsThu, 18 Jul 2013 19:43:31 +0000http://www.spraytm.com/?p=4500Event Will Move to Pier 92 on May 14 – 15, 2014

LUXE PACK NEW YORK, the premier show for creative packaging which attracted a record-breaking 2,894 unique visitors in May, will relocate to Pier 92 for its next edition, May 14-15, 2014. The new venue will allow all the exhibitors and attractions to be positioned on the same floor.

“We are very proud of LUXE PACK NEW YORK’s tremendous success over the last 11 years. This year, at peak hours the aisles were overflowing with visitors and the seminar room was overcrowded. The venue has been very popular, however today, we have simply outgrown it. Our goal is to continue to create the best possible environment for our high level exhibitors and visitors to connect. Pier 92 is the ideal space in which to maintain our standard of service as we continue on the path of controlled steady growth,” said Nathalie Grosdidier, Executive Director, LUXE PACK.

Pier 92, located at 711 12th Avenue at 55th Street, is a premium exhibition and event space in the heart of midtown Manhattan featuring a column-free space with high ceilings and unlimited views of the Hudson River. www.luxepack.com

BAMA, the British Aerosol Manufacturers’ Association (BAMA) will hold its annual Forum on Oct. 17–18, with the Awards Dinner on Oct. 17, open to all BAMA members. The two-day BAMA Forum will cover topics such as leak detection, HFO-1234ze for personal care, Authorized Economic Operator scheme, FEA update, compressed aerosol products, spray technology and dry shampoos. Business topics include alternative sources of finance and counterfeiting; and a presentation from Professor Tim Jacob of Cardiff University on olfaction and fragrance in aerosols entitled “Smell is a potent wizard.” There will also be space for members to showcase products and services.

Now in its fifth year, the BAMA Awards recognize and promote the high standards in the UK aerosol industry. They will be presented at a gala dinner where guests will be entertained by acclaimed comedian, writer, broadcaster and GP, Dr. Phil Hammond.

This year, for the first time, there are rewards for BAMA members who enter the Awards and prizes worth a total of £3,000 ($4,500) for the companies who are picked as winners or runners-up in two of the categories.

Companies engaged in any aspect of the aerosol industry, but who are not already members of BAMA, may enter the Awards and apply to attend the Forum and gala dinner as long as they have applied for membership and have their application accepted before the closing date for entries, Sept. 6. More info: BAMAAdmin@bama.co.uk

The Alliance for Consumer Education’s (ACE) Strike Out Inhalants was established in 2008 and has been growing ever since. ACE has worked with an array of Major and Minor League Baseball Teams to help spread inhalant abuse prevention messaging.

Each game and partnership is different, but some aspects from the Strike Out Inhalants program include:

Assemblies and presentations with school aged children; hosted by the participating team, where players and mascots go out into schools to show, as role models, why abusing inhalants is dangerous

Tickets to an “Awareness Night” game to all students who attend the assembly

Strike Out Inhalants Awareness Night, Which includes

Baseball game attended by students, families, and ACE

ACE materials and resources offered to fans free of charge at ACE sponsored table in the concourse

Pre-game presentation on the dangers of inhalant abuse

Pre-game and during the game PSAs that air between innings

Pre-game questions on the video board to help fans learn more about inhalants

Strike Out Inhalants Pledge read aloud by the stadium or singed by students at the ACE booth

Be an ACE Superhero Coloring Contest

Radio interviews with ACE members, doctors, or families affected by inhalant abuse

In stadium media including a Strike Out Inhalants banner in the concourse

Summer 2013 Schedule of Strike Out Inhalants Games

This summer ACE will be working with the following teams and organizations to spread awareness on inhalant abuse.

See more at: http://www.inhalant.org/about-us/baseball/#sthash.dJojtVUX.dpuf

]]>http://www.spraytm.com/swing-into-summer-with-ace.html/feed0ICMAD Hosts Key Information Sessions At Cosmoprof North Americahttp://www.spraytm.com/icmad-hosts-key-information-sessions-at-cosmoprof-north-america.html
http://www.spraytm.com/icmad-hosts-key-information-sessions-at-cosmoprof-north-america.html#commentsTue, 09 Jul 2013 18:57:36 +0000http://www.spraytm.com/?p=4481On Monday, July 15, join the Independent Cosmetic Manufacturers and Distributors (ICMAD) for two invaluable presentation sessions during Cosmoprof North America in Las Vegas (July 14-16). Take a break from the world’s leading beauty trade show and join ICMAD for important updates on the latest, frontline industry regulations and learn how they will affect your business.

Breakfast Break for Beauty News Speaker Presentation(8:30am to 10:00am, Lagoon G area, Mandalay Bay)
ICMAD will walk you through the current U.S. and international regulatory changes facing the beauty industry. A panel of expert speakers that includes ICMAD President and CEO Pam Busiek; Edwards Wildman and Palmer Of Counsel and ICMAD Government Relations Committee Chair Sharon Blinkoff; Carl Geffken & Associates President and ICMAD International Relations Chair Carl Geffken; PCPC Executive VP Government Affairs John Hurson;plus Consumer Product Testing Company President and ICMAD Technical/Regulatory Committee Chair Craig Weiss will present a global overview of today’s cosmetic regulations. From the effects of regional consumer concerns on the overall marketplace to safety regulations, this panel will cover everything you need to know for your business to thrive.

It’s All in the Details: A Legislative Update Presentation

(11:00am, Jolie Conference Room #2, Mandalay Bay)

Three top industry leaders—PBA Executive Director Steve Sleeper; PCPC Executive VP Government Affairs John Hurson; and ICMAD President and CEO Pam Busiek—will enlighten guests on current state and federal legislative activities that directly impact the beauty industry. To protect industry interests, these top three associations, ICMAD, PBA, and PCPC, have banded together as one voice as a pro-active advocate. Knowledge is power for this must-attend event.

WHAT IT COSTS: “Breakfast Break for Beauty News” $45 register at www.icmad.com, “It’s All in the Details: A Legislative Update” complimentary to all Cosmoprof attendees. Register for Cosmoprof North America at www.cosmoprofnorthamerica.com.

]]>http://www.spraytm.com/icmad-hosts-key-information-sessions-at-cosmoprof-north-america.html/feed0Aerosol foods shorten prep time for a variety of categories.http://www.spraytm.com/aerosol-foods-shorten-prep-time-for-a-variety-of-categories.html
http://www.spraytm.com/aerosol-foods-shorten-prep-time-for-a-variety-of-categories.html#commentsMon, 01 Jul 2013 19:00:57 +0000http://www.spraytm.com/?p=4688World demand for food containers is forecast to increase 3.9% per year to $124 billion in 2013, according to market research from The Freedonia Group. Factors contributing to rising demand include growth in global food output and trends toward convenience-oriented food options as a result of fast-paced lifestyles.

Demographic trends such as the growing percentage of urban population in the workforce, coupled with increases in the number of single-person households, will also influence food container demand. This will fuel consumer spending on packaged and processed foods, due to more limited time for meal preparation and convenience benefits.

While the U.S. is by far the world’s largest user of food containers, the most rapid increases will occur in the world’s developing regions, said The Freedonia group. Asia, Latin America, Eastern Europe and the Africa/Middle East region will all outpace the global average. Rising consumer income levels, population growth and expanding middle classes will also generate robust internal demand for packaged consumer goods, boosting food container consumption. Some of the best gains are expected in Brazil, Russia, India and China. In particular, China alone is expected to account for nearly one-quarter of global value gains in food containers.

Sweet & savory, quick & tasty

Convenient and fast food preparation without sacrificing taste or presentation is what aerosol foods are all about.

According to the company, Gavora oils and vinegars are 100% pure product, with no propellants, preservatives or additives. Products also stay fresh longer and are eco-friendly due to a bag-on-valve (BOV) packaging system. This system protects product from the spoiling influences of light and air, keeping the contents fresher for longer. No chemical propellants or additives are needed to dispense the products and every component of the packaging is 100% recyclable, according to BOV Solutions, who supplied the packaging.

BOV Solutions states it is the first bag-on-valve manufacturer to become Safe Quality Food Institute (SQF) Level 3 certified, indicating a comprehensive implementation of food safety and quality management systems development.

Available in select retailers and online beginning last May, Serendipity Salad Dressings and Dips show that “healthy food” and “great flavor” can go hand in hand. Made of real dressing and in six flavors, including Blue Cheese, Honey French, Caesar, Ranch, Creamy Italian and Thousand Island, Serendipity is only 15 calories per serving. It has 90% fewer calories, carbs, sugar, fat and sodium than other leading dressings and has no trans-fat, cholesterol, artificial colors or sweeteners.

Serendipity’s delivery mechanism, from Clayton Corp., aerates the dressings and dips as they are released, allowing it to hold a “whipped” profile. Because of the whipped nature of the product, Serendipity also has built-in portion control.

Created by New York investor and entrepreneur Jimmy Lee, Serendipity was born in part, thanks to Lee’s background as a healthcare venture capitalist.

“Working as an investor in startup drug and medical device companies, I became all too familiar with the long-term effects that poor dietary habits can have on overall health,” said Lee. “I thought focusing on the root problem of obesity, diabetes, and cardiovascular disease through healthy eating was a more productive route than finding costly and difficult ‘cures’ that are ineffective. Serendipity was born out of a desire to spur easy healthy eating habits without sacrificing taste.”

While developing the product, Lee connected with celebrity chef David Burke, who liked Serendipity’s product so much he joined the company as the Chief Culinary Advisor.

Liquor Whipped from Temperance Distilling Co. is a vodka-infused whipped cream with a delicate blend natural flavors and the light creamy texture of decadent whipped cream to liven up parties, top off drinks or enhance desserts. Flavors include Chocolate, Vanilla, Irish Mint, Piña Colada, White Chocolate Peppermint (in both a Christmas and St. Valentine’s Day decorated can), Caramel, Key Lime Pie, Orange, Strawberry, Raspberry and Cherry.

Not only is there real whipped cream infused with alcohol, but now there’s real whipped cream infused with wine. At 27 proof or 13.5 % alcohol, Whipsy Whipped Cream from Big Easy Blends LLC can really take the enjoyment of that slice of pie to another level. Available in three flavors—Ooh-La-La Original, Hazey Hazelnut and Loco Cocoa—it can also be dispensed into cups, placed in the freezer and eaten like ice cream.

Non-alcoholic FOMZ Zero Gravity Fruit from Sun Orchard Inc. is a new, fruit-infused foam available in three flavors: Lemon Lime, Passionfruit Mango and Wild Berry. FOMZ is intense, frothy and easy-to-use, contains no dairy, is fat free, low calorie and made with real fruit and pure cane sugar. The cans for FOMZ, Liquor Whipped and Whipsy Whipped Cream are all manufactured by DS Containers.

A big part of this new interest in aerosol foods, he added, is the fact that they help reduce household food waste, which has become an epic issue in major markets. According to recent published reports, the average U.S. family throws out between 14% and 25% of the food and beverages they buy, accounting for as much as $2,275 annually, Brand pointed out. A similar report from the UK states that consumers throw out 11.9 million tons of food yearly, or .45 tons per household.

“Practicality and efficiency are consumer hot buttons that give rise to aerosol food interest from consumer brands as well as the traditional food service industry,” said Brand. “As new technology opens the way for mind-boggling new food launches, savvy companies from multinationals to nimble entrepreneurial firms see opportunities with aerosol-based foods.”

Important is the fact that aerosol-packaged foods are protected from light and air, thus enhancing hygienic appeal. They are designed for precise, efficient usage. Waste and mess are minimized, as the consumer only uses what is needed, when it is needed.

“With value such a huge consumer driver these days, the reduced waste of aerosol foods is appealing,” Brand said. “And they are lots of fun to use.”

The latest U.S. foods packaged in Lindal-sourced aerosol platforms include Inventi Coffee concentrate blend, distributed by HGF Brands LLC. Inventi is made of a blend of coffee beans from Peru, Colombia, Venezuela, Mexico and Vietnam. Each aerosol container has 35 servings ready to create lattes, iced coffees, milkshakes and desserts. Consumers simply shake and spray the desired amount into a cup (for mild or strong), add ice and milk, and stir. It can also be added to baking recipes, dinner dishes and drink mixes. The product is available in Original, Caramel, Mocha and Vanilla.

There have been several new launches for Lindal in Europe, as well. Natur’ Mousse from Sens Gourmet is a fruit-flavored mousse. Flavors include Raspberry, Banana, Passionfruit, Strawberry, Mango and Kiwi. The company is planning a launch of a vegetable-flavored mousse by the end of this year.

Les Syphonés launched chocolate mousse and cheese mousses (in Plain, Goat, Tomato Basil and Fresh Herb) with a new, washable actuator developed by Lindal. The mousses are filled by Coltivia.

In Spain, a churro is a fried pastry, typically eaten as a dessert and with a chocolate beverage. Masa de Churro (Churro Dough) for direct frying comes from Spanish company New Food Spray, along with aerosol pastry cream and blini and pancake batter.

“Consumers are more adventurous in their food purchases and innovative new platforms that deliver quality, wholesome consumer food products will win retail support,” concluded Brand. “In the near future, we envision new worlds of sauces, instant cookies and muffins…if you can dream it, we can make it happen.” SPRAY

Aerosol foods shorten prep time for a variety of categories.

World demand for food containers is forecast to increase 3.9% per year to $124 billion in 2013, according to market research from The Freedonia Group. Factors contributing to rising demand include growth in global food output and trends toward convenience-oriented food options as a result of fast-paced lifestyles.

Demographic trends such as the growing percentage of urban population in the workforce, coupled with increases in the number of single-person households, will also influence food container demand. This will fuel consumer spending on packaged and processed foods, due to more limited time for meal preparation and convenience benefits.

While the U.S. is by far the world’s largest user of food containers, the most rapid increases will occur in the world’s developing regions, said The Freedonia group. Asia, Latin America, Eastern Europe and the Africa/Middle East region will all outpace the global average. Rising consumer income levels, population growth and expanding middle classes will also generate robust internal demand for packaged consumer goods, boosting food container consumption. Some of the best gains are expected in Brazil, Russia, India and China. In particular, China alone is expected to account for nearly one-quarter of global value gains in food containers.

Sweet & savory, quick & tastyConvenient and fast food preparation without sacrificing taste or presentation is what aerosol foods are all about.

Gavora Naturals offers 100% Pure Canola Oil, Canola Oil with Butter Flavor, Peanut Oil, Extra Virgin Olive Oil, 100% Organic Italian Extra Virgin Olive Oil, Grape Seed Oil, 12 Star Balsamic Vinegar and Premium 25 Star Balsamic Vinegar. Gavora’s spout helps make product use neat and simple, as the user can control whether the oil drips, streams or sprays out of the can by adjusting finger pressure on the soft pad of the special actuator.
According to the company, Gavora oils and vinegars are 100% pure product, with no propellants, preservatives or additives. Products also stay fresh longer and are eco-friendly due to a bag-on-valve (BOV) packaging system. This system protects product from the spoiling influences of light and air, keeping the contents fresher for longer. No chemical propellants or additives are needed to dispense the products and every component of the packaging is 100% recyclable, according to BOV Solutions, who supplied the packaging.

BOV Solutions states it is the first bag-on-valve manufacturer to become Safe Quality Food Institute (SQF) Level 3 certified, indicating a comprehensive implementation of food safety and quality management systems development.

Available in select retailers and online beginning last May, Serendipity Salad Dressings and Dips show that “healthy food” and “great flavor” can go hand in hand. Made of real dressing and in six flavors, including Blue Cheese, Honey French, Caesar, Ranch, Creamy Italian and Thousand Island, Serendipity is only 15 calories per serving. It has 90% fewer calories, carbs, sugar, fat and sodium than other leading dressings and has no trans-fat, cholesterol, artificial colors or sweeteners.

Serendipity’s delivery mechanism, from Clayton Corp., aerates the dressings and dips as they are released, allowing it to hold a “whipped” profile. Because of the whipped nature of the product, Serendipity also has built-in portion control.
Created by New York investor and entrepreneur Jimmy Lee, Serendipity was born in part, thanks to Lee’s background as a healthcare venture capitalist.

“Working as an investor in startup drug and medical device companies, I became all too familiar with the long-term effects that poor dietary habits can have on overall health,” said Lee. “I thought focusing on the root problem of obesity, diabetes, and cardiovascular disease through healthy eating was a more productive route than finding costly and difficult ‘cures’ that are ineffective. Serendipity was born out of a desire to spur easy healthy eating habits without sacrificing taste.”

While developing the product, Lee connected with celebrity chef David Burke, who liked Serendipity’s product so much he joined the company as the Chief Culinary Advisor.
Liquor Whipped from Temperance Distilling Co. is a vodka-infused whipped cream with a delicate blend natural flavors and the light creamy texture of decadent whipped cream to liven up parties, top off drinks or enhance desserts. Flavors include Chocolate, Vanilla, Irish Mint, Piña Colada, White Chocolate Peppermint (in both a Christmas and St. Valentine’s Day decorated can), Caramel, Key Lime Pie, Orange, Strawberry, Raspberry and Cherry.
Not only is there real whipped cream infused with alcohol, but now there’s real whipped cream infused with wine. At 27 proof or 13.5 % alcohol, Whipsy Whipped Cream from Big Easy Blends LLC can really take the enjoyment of that slice of pie to another level. Available in three flavors—Ooh-La-La Original, Hazey Hazelnut and Loco Cocoa—it can also be dispensed into cups, placed in the freezer and eaten like ice cream.

Non-alcoholic FOMZ Zero Gravity Fruit from Sun Orchard Inc. is a new, fruit-infused foam available in three flavors: Lemon Lime, Passionfruit Mango and Wild Berry. FOMZ is intense, frothy and easy-to-use, contains no dairy, is fat free, low calorie and made with real fruit and pure cane sugar. The cans for FOMZ, Liquor Whipped and Whipsy Whipped Cream are all manufactured by DS Containers.

A new world of sauces, instant cookies and muffins…
The rising tide of innovative, convenient, healthy and waste-reducing new food products dispensed from aerosol containers reflects sharp changes in consumer priorities, explained Philip Brand, Global Marketing Director for Lindal Group.

A big part of this new interest in aerosol foods, he added, is the fact that they help reduce household food waste, which has become an epic issue in major markets. According to recent published reports, the average U.S. family throws out between 14% and 25% of the food and beverages they buy, accounting for as much as $2,275 annually, Brand pointed out. A similar report from the UK states that consumers throw out 11.9 million tons of food yearly, or .45 tons per household.

“Practicality and efficiency are consumer hot buttons that give rise to aerosol food interest from consumer brands as well as the traditional food service industry,” said Brand. “As new technology opens the way for mind-boggling new food launches, savvy companies from multinationals to nimble entrepreneurial firms see opportunities with aerosol-based foods.”

Important is the fact that aerosol-packaged foods are protected from light and air, thus enhancing hygienic appeal. They are designed for precise, efficient usage. Waste and mess are minimized, as the consumer only uses what is needed, when it is needed.
“With value such a huge consumer driver these days, the reduced waste of aerosol foods is appealing,” Brand said. “And they are lots of fun to use.”

The latest U.S. foods packaged in Lindal-sourced aerosol platforms include Inventi Coffee concentrate blend, distributed by HGF Brands LLC. Inventi is made of a blend of coffee beans from Peru, Colombia, Venezuela, Mexico and Vietnam. Each aerosol container has 35 servings ready to create lattes, iced coffees, milkshakes and desserts. Consumers simply shake and spray the desired amount into a cup (for mild or strong), add ice and milk, and stir. It can also be added to baking recipes, dinner dishes and drink mixes. The product is available in Original, Caramel, Mocha and Vanilla.

There have been several new launches for Lindal in Europe, as well. Natur’ Mousse from Sens Gourmet is a fruit-flavored mousse. Flavors include Raspberry, Banana, Passionfruit, Strawberry, Mango and Kiwi. The company is planning a launch of a vegetable-flavored mousse by the end of this year.

Les Syphonés launched chocolate mousse and cheese mousses (in Plain, Goat, Tomato Basil and Fresh Herb) with a new, washable actuator developed by Lindal. The mousses are filled by Coltivia.

In Spain, a churro is a fried pastry, typically eaten as a dessert and with a chocolate beverage. Masa de Churro (Churro Dough) for direct frying comes from Spanish company New Food Spray, along with aerosol pastry cream and blini and pancake batter.

“Consumers are more adventurous in their food purchases and innovative new platforms that deliver quality, wholesome consumer food products will win retail support,” concluded Brand. “In the near future, we envision new worlds of sauces, instant cookies and muffins…if you can dream it, we can make it happen.” SPRAY

CARB
In April, the California Air Resources Board (CARB) made some significant modifications to their proposed amendments to their Consumer Products volatile organic compound (VOC) regulations.

CARB modified the proposed limits for the Aerosol Coatings categories. The new limits will be challenging, to say the least. For the General Coating Categories, industry will have until 1/1/2017 to comply.

CARB moved the Web Aerosol Adhesive category to a higher limit. Mist Spray still remains at 30%. This limit will be extremely difficult to meet.

The LVP-VOC definition changes were dropped for now, pending scientific studies to be performed by CARB. This was a significant change and was due in a major part by Industry comments to CARB requesting scientific research in this area.
Multi-purpose Solvent and Paint Thinner categories will have modifications to the categories but will only affect product sold in the South Coast Air Quality Management District.

However, in May, CARB delayed the board hearing for these amendments from July until Sept. 26–27. A new proposal is to be sent out before the board hearing. Hopefully, modifications to the amendments that were made in April will remain.

Other changes to the Consumer Products Rule include:

Change to General Purpose Degreaser definition.

Definitions added for Specialty Purpose Cleaners and Special Purpose Degreaser.

The newest version of the amendments should be out soon. CARB has to release their final version of their amendments 45-days before the Sept. 26–27 board hearing. Everyone should review the amendments to the Consumer Products Regulation and the Aerosol Coating regulation. The current proposed changes can be found athttp://www.arb.ca.gov/consprod/regact/2013/2013ra.htm.

Ozone Transport Commission
The Ozone Transport Commission (OTC) held its last meeting on June 13, 2013 in New Haven, CT. As everyone should know by now, OTC adopts regulations adopted by CARB. Therefore, it is very important to monitor the OTC activity to ensure that the regulations that OTC adopts are similar and consistent with CARB. As an industry, we do not want a patchwork of regulations throughout the country.

Utah
On June 5, 2013 the Utah Air Quality Board adopted a VOC regulation on Consumer Products. The Utah Division on Air Quality (DAQ) proposed a Consumer Products regulation that was similar to the OTC regulations. Its process moved extremely quickly. The rule was posted in March 2013 and adopted in June 2013.
Yet another reason Industry needs to monitor the rules at OTC. Utah staff used OTC as the model for their rules. Utah rules will take effect on Sept. 1, 2014.

National Conference on Weights & Measures
The National Conference on Weights & Measures (NCWM) will meet in Louisville, KY on July 14–18. The issue of whether Bag-on-Valve (BOV) products will need to declare their net contents by weight or volume will once again be discussed. SPRAY

“It takes many good deeds to build a good reputation, and only one bad one to lose it.” Benjamin Franklin

The U.S. Department of Transportation’s (DOT) Pipeline & Hazardous Materials Safety Administration (PHMSA) published its final rulemaking, HM-258, on April 17, 2013. It revises the minimum and maximum civil penalties for “knowingly” violating the federal hazardous materials transportation law, regulation, order, special permit or approval issued under that law.

The maximum civil penalty, as amended by the Moving Ahead for Progress in the 21st Century Act (MAP-21) signed into law on Oct. 1, 2012, is increased from $55,000 to $75,000 for each violation. The maximum civil penalty is increased from $110,000 to $175,000 for each violation that results in death, serious illness or injury to any person, or substantial destruction of property. In addition, the final rule eliminates the $250 minimum civil penalty that can be assessed, except for a violation of a training requirement. In those cases, the minimum civil penalty that is assessed for a training-related violation is increased from $250 to $450.

“Knowlingly” Defined
Unfortunately, there are many respondents to a proposed civil penalty action that use the “unknowingly” defense when explaining their failure to comply with the Hazardous Materials Regulations. You will not find the term “knowingly” defined anywhere in the Hazardous Materials Regulations in 49 CFR subchapter C. One must read the Hazardous Materials Transportation Act, as amended, and precedent case law to see the term defined. The term is also defined in the U.S. Postal Service (USPS) Regulations at 39 United States Code (U.S.C.) § 3018.

Although the offender may not have any direct or indirect knowledge of the alleged offense(s), the DOT does not define the term “knowingly” violating the HMR as having direct or indirect knowledge. DOT defines “knowingly” as “…actual knowledge of the facts giving rise to the violation…” or “…that a reasonable person acting in the circumstances and exercising reasonable care would have had that knowledge.” To date, no one has ever used the “I’m not a reasonable person” or “I did not exercise reasonable care” defense successfully.

In short, it’s not what you knew, but what you should have known.

Hidden Hazardous Materials
Despite the increase in enforcement, sensitivity to security issues, and well publicized accidents and civil penalty cases, hazardous materials are still being shipped illegally through the mail and by common carriers.

Many shippers erroneously assume if a hazard warning label or shipping paper is not required, then the hazardous material is not regulated. I have heard more than one shipper say, on occasion, “Oh, its not regulated…it’s ORM-D!” That is precisely what ORM-D means: “Other Regulated Material, Category D.” In those cases where a shipper fails to provide the required Consumer Commodity ORM-D marking, the shipper may have “unknowingly” committed 24 separate, but distinct, hazardous materials violations, punishable by a civil penalty of up to $1.8 million.

The DOT is of the opinion that, if a shipper makes no effort to communicate the risks associated with a hazardous material by applying the required marks and labels, or preparing and offering a dangerous goods declaration, then the shipper is not entitled to any regulatory relief that they might have otherwise enjoyed had they made the effort to comply with the rules.

A simple mistake, such as leaving off the ORM-D marking on a fiberboard box that contains a dozen aerosol cans, for example, would subject the shipper to a maximum civil penalty of $1.8 million for failure to: properly mark and label the package with the correct, proper shipping name, identification number, hazard warning labels, package the materials into UN approved fiberboard boxes, and offer a dangerous goods declaration, which includes the correct basic description (in the order required), additional descriptive information, emergency response information and telephone number, packaging information, shipper’s certification and signature.

Furthermore, the DOT will tack on violations for not providing training, because the hidden hazardous materials shipment itself would constitute prima fascia evidence that the shipper was not properly trained.

All of the individual offenses arise of out the simple failure to properly mark the package with the minimum required marking—in this case, the proper shipping name (Consumer Commodity), and the hazard class (ORM-D), within a rectangle having dimensions at least one-quarter inch greater on all sides than the ORM-D designation itself. This is what regulatory enforcement agents call “stacking the case.” These types of cases are very hard to defend against and more often than not, the Respondent will pay a substantial penalty as a compromise to settle the proposed civil penalty.

Quite simply, under this new rule, if you make a mistake, get out your checkbook. Be prepared to pay a hefty fine if you “knowingly” or even “unknowingly” commit a violation of the HMR. I guess the best advice that I might offer to any shipper is this: “When in Doubt, Leave it Out!” If you’re not sure, don’t ship. Call and ask for assistance. SPRAY

]]>http://www.spraytm.com/make-a-mistake-get-out-your-chekbook.html/feed0Spray package metal, internal coating and laminate film anomalies and their relationship to aluminum spray package corrosion.http://www.spraytm.com/spray-package-metal-internal-coating-and-laminate-film-anomalies-and-their-relationship-to-aluminum-spray-package-corrosion.html
http://www.spraytm.com/spray-package-metal-internal-coating-and-laminate-film-anomalies-and-their-relationship-to-aluminum-spray-package-corrosion.html#commentsMon, 01 Jul 2013 04:01:21 +0000http://www.spraytm.com/?p=4403Aluminum spray package metals, internal coatings and laminate films are far from perfect (I will hereafter refer to coatings and laminate films as polymers). Indeed, the polymers are not always continuous (i.e., they have holes) and the metal surface is a complex mixture of different crystal structures and non-metallic materials.

In addition, a variety of aluminum alloys are used to fabricate aluminum spray packages. The different alloys often have different surface morphologies and thus polymers form different types of bonds with each type of morphology. The wide variety of polymer-metal bonds produces opportunities for spray package metal and polymer corrosion.
Anomalies on metal surfaces and anomalies in polymers could theoretically cause package corrosion. However, corrosion does not always occur when metal or polymer anomalies are present.

Let’s take a look at a few examples of the spray package metal and polymer anomalies, and discuss their relationship to spray package corrosion.

Figure 1. Hole in a polyacrylamide (PAM) coating

The anomaly in Figure 1 is a hole commonly found in internal coatings for aluminum aerosol containers. The hole directly exposes the aluminum metal to your formula.
Corrosion in aluminum aerosol containers does not occur at the same frequency as the holes. Consequently, holes in coatings do not necessarily lead to container corrosion.Figure 2. Divot in aluminum filled with coating (~0.2 mm wide along the minor axis)

The anomaly in Figure 2 is an example of a divot on the metal surface that was created when a small piece of aluminum metal was torn from the metal during container fabrication. The coating flowed into the hole during coating application inside the container. Corrosion with this type of anomaly is rare.

Figure 3. Solvent pop

Figure 3 has an example of a solvent pop. Solvent pops are very common with lacquer coatings, such as polyacrylamide (PAM). Small bubbles are created during heating to remove the solvent, and the bubbles produce solvent pops like that in Figure 3. Corrosion caused by solvent pops is also rare.Figure 4. Coating drool

The anomaly in Figure 4 is referred to as a drool. Drools form toward container bottoms when coating material drips from the spray nozzle used to apply the coating to the container. I’ve not observed instances where drools caused or contributed to corrosion.